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Climate change adaptation: from the PNACC to the DNSH statement

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The introduction to the National Climate Change Adaptation Plan (NACCP) plays a key role in the context of climate change management. 

This tool  strategic provides an overview of the challenges that climate change presents to the national context, as well as strategies and planned actions to mitigate negative impacts and take advantage of emerging opportunities.

Let’s explore together the legal process that led to the introduction of the PNACC into the Italian legal system, its practical implications, and the link between the plan’s objectives and the Do Not Significant Harm (DNSH) principle that underlies the measures in the PNRR. 

The National Climate Change Adaptation Plan: structure and function

The Minister of Environment and Energy Security (MASE), through Decree no.
434 of Dec. 21, 2023, approved the PNACC, National Climate Change Adaptation Plan.

It was a key step in planning and implementing climate change adaptation actions in Italy, in line with international measures on the issue, such as the Adaptation Strategy that the European Commission published in 2021. 

The Plan is the result of a series of environmental initiatives that began in 2015, when the Ministry of the Environment developed a strategic document containing action criteria for coping with climate change, namely the National Climate Change Adaptation Strategy (SNAC). 

After a lengthy approval process, the MASE approved the National Climate Change Adaptation Plan in December 2023: a programmatic document with 300 containment measures and adaptation strategies for phenomena such as global warming and resulting natural events. 

The structure of the PNACC is as follows:

1. Legal framework;

2. National climate framework;

3. Impacts of climate change in Italy and sectoral vulnerabilities;

4. PNACC measures and actions;

5. Funding arrangements for climate change adaptation;

6. Adaptation governance.

On the one hand, PNACC aims to build an organizational framework marked by the establishment of governance structure and criteria and knowledge development; on the other hand, it builds a framework for the planning and implementation of concrete actions to be taken as measures to combat and contain climate change. 

The DNSH statement and ecosystem protection measures.

In the context of international measures to protect the global ecosystem is EU Regulation 2020/852, which outlined the so-called Taxonomy for Sustainable Finance: a classification system for sustainable economic activities that identifies the six criteria useful for determining whether an activity, intervention or investment project contributes to the protection of the ecosystem, without causing significant harm to the environment, i.e., the so-called Do Not Significant Harm (DNSH) principle. 
The criteria outlined by the DNSH principle, precisely the DNSH criteria, are the basis for all interventions under the National Recovery and Resilience Plan. 
It is the NRP itself that stipulates that an intervention or investment project, in order to comply with the DNSH principle, and to access benefits under the Plan, must meet the requirements that the EU Regulation calls “Climate Targets,” namely: 
  • Do not cause significant greenhouse gas emissions (Climate Goal 1 – Climate Change Mitigation);
  • not bring greater negative impacts on current and future climate, people, nature and property (Climate Goal 2 – Climate Change Adaptation);
  • not harm the status of water bodies, nor lead to the deterioration of their quality or the reduction of their ecological potential (Climate Goal 3 – Sustainable use and protection of water and marine resources);
  • not cause significant inefficiencies in the use of recycled or recovered materials, does not fuel the growth of waste, its incineration or disposal, causing long-term environmental damage (Climate Goal 4 – Transition to Circular Economy);
  • not result in the increase of harmful emissions to air, soil and water (Climate Goal 5 – Pollution Prevention and Control);
  • not damage the good condition and resilience of ecosystems, the conservation status of habitats and species (Climate Goal 6 – Protection and restoration of biodiversity and ecosystem health). 
The principle of “Do Not Significant Harm” (DNSH) is closely related to the National Climate Change Adaptation Plan in that both focus on responsible management of environmental and social impacts, including those resulting from climate change.

DNSH declaration for companies: when is it mandatory?

Companies that want to access financial resources under the National Recovery and Resilience Plan, in order to carry out investment projects or interventions, must demonstrate that these are not harmful to the environment and in line with the climate objectives under the DNSH principle. 
When reporting on the project, it is necessary to submit the so-called.
“Declaration of DNSH compliance,” indicating all requirements aimed at verifying compliance with the climate objectives outlined in EU Regulation 2020/852.  
In addition to being a requirement for access to facilities, preparing the DNSH declaration also has reputational benefits for companies , as it is a certified source of their sustainable commitment and a record of compliance with regulatory obligations on the subject. 

Process the DNSH Declaration with the support of Tecno

Demonstrating the compliance of an investment project is not a simple process, as it consists of detailed analyses related to the stage of its development, writing and submission. 
These analyses involve a careful assessment of the environmental impact that the process, product or service offered through the project has throughout its life cycle. 
At Tecno, we can offer you concrete support in verifying that your project or intervention complies with the DNSH principle, making it easier to obtain funding and facilities under the NRP. 
Demonstrate your project’s compliance with EU climate goals, 
We build the sustainable growth of your business. 
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Registered office: Riviera di Chiaia 270
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Tax Code / VAT Number: 08240931215
N. R.E.A.: NA 943077
Shared Capital. € 50.000,00 i.v.

2024 © Tecno S.r.l.

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