Written evidence submitted by Dr Alice Venn, Senior Lecturer in Climate Law, University of Bristol, Dr Sarah Bell, Senior Lecturer in Health Geography, University of Exeter, and Andrew Shipley, Researcher, University of Exeter (ICP0015)

The authors:

Dr Alice Venn (Senior Lecturer in Climate Law, University of Bristol), Dr Sarah Bell (Senior Lecturer in Health Geography, University of Exeter), Andrew Shipley (Researcher, University of Exeter) on behalf of the UKRI-funded Sensing Climate project on disability-inclusive climate policy. Our experience and expertise span the areas of public policy, disability, environmental inclusivity, climate law and policy, human rights and equalities frameworks. 

UK Government Leadership

How do the UK’s 2030 and 2035 Nationally Determined Contributions (NDCs) impact domestic climate action, and how does it compare globally on NDCs?  

We respectfully wish to highlight some omissions in the 2035 NDC which raise concerns with respect to the inclusivity of climate policy at both the international and domestic levels. The NDC plays an important role in shaping domestic climate policy responses, particularly how the just transition to net zero is approached looking ahead to our interim and longer-term 2050 targets. The 2035 NDC does not make any reference to disability or to the unique needs and experiences of disabled people, who, research has shown, are disproportionately impacted by climate change and are often overlooked in climate policy design[1]. This can result in non-compliance with equalities and human rights duties under the Equalities Act [2010] and the Human Rights Act [1998] at the domestic level, as well as non-compliance with positive duties of the state under European and international human rights law, including the European Convention on Human Rights, the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic Social and Cultural Rights (ICESCR), and the Convention on the Rights of Persons with Disabilities (CRPD) respectively. 

1. The NDC does not contain a commitment to adopting a ‘rights-based approach’ to climate action (compared to the EU’s NDC which does so in paragraph 108). The NDC currently makes only one reference to a human right – the right to health in relation to air pollution measures. This is not in alignment with either UN climate policy approaches increasingly affirmed through the Paris Agreement[2], UN Framework Convention on Climate Change (UNFCCC) loss and damage and just transition workstreams, or the emerging jurisprudence of international and regional human rights bodies. These include the courts and treaty bodies of human rights instruments that the UK is party to, notably the UN Human Rights Committee that has affirmed the existence of positive duties to address the human rights impacts of climate change[3] and the Committee on the Rights of Persons with Disabilities. The latter has affirmed in many concluding observations on States Parties’ individual reports as well as in joint recommendations with other committees, the need to take positive measures to consider the needs and ensure the participation of disabled people in climate mitigation and adaptation policy design[4]. The International Court of Justice Advisory Opinion on Climate Change and the European Court of Human Rights climate case law, including the significant procedural and substantive obligations detailed in the Klimaseniorinnen v Switzerland[5] case, further underline the need to comprehensively integrate rights into the UK’s international and domestic climate policies. These courts and treaty bodies collectively affirm the intersecting obligations of states under human rights and climate law frameworks, with a particular focus on disproportionately impacted groups such as disabled people.

2. The NDC makes just one reference to the Equality Act (2010) with respect to gender-responsive action and the need for public authorities to ‘fulfil responsibilities’ when implementing policies to meet the 2035 NDC. The narrow framing of this policy provision overlooks the wide-ranging responsibilities associated with the public sector equality duty (PSED) to take into consideration the impacts on disabled people of climate policies which have been the subject of successive judicial review actions brought by Friends of the Earth and others[6].

3. The lack of recognition of disability rights and equalities impacts for disabled people leads to an accountability gap in government climate policy and a lack of focus on these issues in domestic climate policy rollout, with adverse impacts through ‘eco-ableism’ both at the national and local governance levels[7]. Public bodies are lacking a clear steer on the relevance and importance of international human rights and climate bodies’ calls for a rights-based approach.

Key recommendations:

1. Embed disability rights into the UK’s international climate policy including in the NDC and negotiating positions within key relevant UNFCCC workstreams, most notably on just transition, and ensure they are embedded in corresponding domestic implementation policies. The following resources should be drawn on to ensure a comprehensive approach, informed by the recommendations of UN bodies, existing UK government strategies, disability research and best practice including:

1. UN Office of the High Commissioner on Human Rights in particular calls within the Synthesis Report on Just Transition and Human Rights[8], and the Analytical Study on the Promotion and Protection of the rights of persons with disabilities in the context of climate change[9]. 
2. Committee on the Rights of Persons with Disabilities – in particular findings of the Committee on States’ compliance with disability rights in the design and implementation of climate policies[10].
3. International Labour Organization and UN Development Programme Guidance Tool on Integrating the Rights of Persons with Disabilities in Nationally Determined Contributions[11].
4. UK Foreign, Commonwealth and Development Office Disability Inclusion and Rights Strategy 2022-2030[12] signposting climate action as a key emerging intervention area including working with partners to accelerate global attention and action institutionalising disability inclusion.
5. Research illustrating the need for an intersectional approach that expressly recognises the needs, rights, and knowledge of disabled people in shaping climate policy responses – see, inter alia, Jodoin et al[13], Bell et al[14], Kelly-Costello et al.[15]

2. Adopt a whole of government, intersectional and rights-based approach that extends beyond the exclusive youth and gender framing currently adopted by the UK NDC and explicitly focuses on the intersectional and structural inequalities that are compounded by climate change across multiple groups. The integration of adaptation and loss and damage measures as recommended by the UNFCCC can also offer additional opportunities for this.

Please see below illustrative examples of wording and approaches from other NDCs (available via UNFCCC registry[16]):

1. European Union 2025 NDC – contains references to the EU Adaptation Strategy which acknowledges that ‘older people, persons with disabilities, displaced persons or socially marginalised have different adaptive capacities’ and that measures ‘need to involve those groups in all their diversity and consider their situation’ (paragraph 109).

2. Fiji NDC 3.0 – core principles and approach include ‘Human rights-based approach: Fiji places the protection of the rights of its citizens, including the right to life, health, food, water, and housing, at the centre of Fiji’s climate response priorities’ and ‘Social Inclusion, Equity, and Gender Responsive Approaches: Climate policies and programmes are designed to be gender-responsive and inclusive and compatible with the unique capacities of all groups in society. This approach focuses on protecting the most vulnerable, including women, children, persons with disabilities, and those in remote and maritime communities, recognizing their distinct and differentiated vulnerabilities to climate change’ (section 1.5.1)

3. Papua New Guinea Second NDC - commits to ‘ensuring [a] gender-responsive and human rights-based approach in all related planning, programming, and implementation. This includes the participation of women, youth and vulnerable groups in consultations, planning and decision making’. It also refers to adaption actions that aim to benefit ‘targeted populations’ including ‘including women, children, young persons, the elderly, and people living with disabilities, members of underprivileged or less advanced groups, or residents of less advanced areas’ (pages 8 and 24).

4. Vanuatu NDC 3.0 – draws on the Disability and Inclusive Development Policy at the domestic level and affirms the Paris Agreement preamble wording on human rights, including people with disabilities. There is also an emphasis on workforce reskilling for persons with disabilities, and an acknowledgement of ‘significant structural and cultural barriers preventing the full and equitable participation of women and girls, children, the elderly, people with disabilities and gender-diverse people across all aspects of sustainable development planning, including climate planning. Vanuatu adheres to the principles of the International Covenant on Civil and Political Rights and other human rights instruments that stipulate that all people have the right to free, active, and meaningful participation’. This includes dedicated outreach to inter alia, persons with disabilities, traditional knowledge holders, and climate displaced persons. The NDC also includes a designated section on people with disabilities for adaptation measures (A74-A76).

Non-state actor involvement and leadership

What role do UK non-state actors have in leading on international climate action and how can the UK Government best support them?

It is essential that the UK government formally recognises the role of non-state actors, in particular civil society organisations, local government representatives, and community groups throughout climate policymaking processes, from the design through to implementation, monitoring and follow-up. Building in an express focus on groups who are underrepresented and disproportionately impacted by climate impacts and climate policy responses themselves in the context of just transition is crucial to avoid reinforcing or compounding existing structural inequalities such as poverty and ableism. Building a strong focus on co-production approaches to policy design, as well as targeted, sensitive and accessible engagement with affected groups including disabled people is called for.

Climate, nature and disabled peoples’ organisations (DPOs) in the UK currently offer many examples of best practice in co-producing climate-related policies, action plans and priorities from the community level, including transferrable guiding principles on just transition that the UK government could platform at the national and international levels. The UNFCCC Just Transition contact groups, for example, provide an opportunity to share knowledge and best practice on implementation approaches and have previously featured case studies from China, South Africa and the Indigenous Peoples negotiating group, among many others. 

Examples of non-state actor led best practice in Bristol, UK:

Examples of good practice with potential as transferrable case studies can be found in Bristol, where a variety of measures have been adopted, including a Just Transition Declaration[17] to guide action with a view to developing a more inclusive approach for the realisation of the Bristol One City Climate Strategy’s net zero target for 2030[18]. The Bristol Community Climate Action Project, funded by the National Lottery, enabled the co-production of a series of climate action plans with diverse communities from across the city, including specific plans for disabled people and refugee communities[19]. The disability-led Community Climate Action Plan that was co-produced with 300 disabled people living or working in the city outlines a series of key priority actions in the areas of transport, housing, food, waste, nature, energy, economy & jobs among others to inform the development of more inclusive climate policy [20]. The groundbreaking Community Leadership Panel on Climate Change and Just Transition which has subsequently been created in Bristol is made up of diverse community advocates who are positioned to review and provide feedback on citywide and regional climate policy proposals[21]. 

Key recommendations:

1. Embed thorough and well-resourced public engagement with a range of stakeholders at the local level in national climate policy approaches and advocate for this internationally, adopting a particular focus on listening to the needs, knowledge and experiences of underrepresented and disproportionately impacted groups in society. This should include meaningful engagement with disabled people with diverse forms of lived experience, taking care to address issues such as climate risk in an accessible and sensitive manner. Detailed guidance on how to approach these conversations with disabled people and DPOs has been launched by the Sensing Climate project team, linked below[22].

2. Platform and support the work of non-state actors, including civil society and local community groups, by creating space in international climate policy processes at the UNFCCC for them to share their learnings and experiences, for example, supporting side events hosted by the UK pavilion at COPs, provision of small grants and logistical advice / support for COP attendance, and encouraging invitations to be issued to address key negotiation sub-groups such as the Just Transition Contact Groups where non-state actors can share their knowledge and better influence global outcomes.

3. Support international efforts to create a disabled people’s negotiating group at the UNFCCC, including the work of key DPOs at the national and international levels such as CBM Global Disability Inclusion[23] on this to increase consideration of their needs in top-down as well as bottom-up policy agendas and to ensure greater compliance with international human rights obligations.

4. Provide funding for research focused on inclusive climate policy solutions, for example, through UKRI, British Academy, and allocated budgets for local authorities to do this accessible and inclusive engagement and co-production work with communities across the UK, with opportunities for this to be fed back and integrated into central climate policy.

December 2025

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