Bridging the Inclusion Gap: Informality and the Promise of Climate Action Plans in Indian Cities

Abstract

City climate action plans (CAPs) in India remain constrained by institutional, financial and governance challenges. A concern is the marginalisation of vulnerable groups, particularly informal settlements and workers, raising questions about equity and the transformative potential of CAPs. This article examines the first generation of CAPs in Mumbai, Bengaluru and Chennai. It adopts a qualitative research design, combining structured textual analysis of CAPs with semi-structured key informant interviews. The analysis reveals how informal settlements and informal workers are identified and prioritised across plan structures, participatory processes and proposed sectoral actions. To foreground alternative pathways, the article also examines select Community-CAPs emerging as forms of practice-based counter-planning. The findings reveal that CAPs acknowledge the vulnerability of informal settlements—and, to a lesser extent, informal workers—but rarely translate into rights-based adaptation strategies. Yet, CAPs have opened a limited but significant potential for longer-term institutional change. The article argues that CAPs may enable localised and tactical forms of inclusion that statutory planning frameworks struggle to accommodate, including pilots, ward-level engagement and co-production through Community-CAPs. The article calls for an India-specific climate action framework that centres informality, equity and justice; strengthens decentralisation; and positions urban local bodies as leaders of inclusive climate governance.

Keywords

Climate Action Plans Informality Informal Settlements Informal Workers Climate Governance

Introduction

Cities are central to both the causes and consequences of climate change. They account for a substantial share of global greenhouse gas emissions while also functioning as critical sites of climate governance and adaptation (Dodman et al., 2019; UNEP, 2017). Rapid urbanisation in the global South, coupled with inadequate infrastructure and service delivery, has intensified emissions and deepened vulnerability to climate risks such as heatwaves, flooding, droughts and air pollution (Kaur & Pandey, 2021; Satterthwaite et al., 2018; Sethi & Vinoj, 2024). Informal settlements accommodate nearly one billion people globally, while informal economies employ close to two billion workers, making these populations among the most climate vulnerable (ILO, 2018; UN-Habitat, 2022). Despite their scale and everyday engagement with climate risks, they remain marginal within formal climate planning processes (Dodman et al., 2019; Oates & Sudmant, 2024).

In India, these climate risks intersect with structural inequalities embedded in processes of urbanisation, informality and governance. Urban poor communities experience a dual burden of environmental exposure and institutional marginalisation, shaped by precarious livelihoods and limited access to state protection (Roy, 2025; Singh et al., 2021; Sverdlik et al., 2024). In response, Indian cities have adopted city climate action plans (CAPs) as key instruments of urban climate governance, aimed at localising efforts in mitigation, adaptation and urban resilience (Singh et al., 2021; Unnikrishnan & Nagendra, 2021). While CAPs employ the language of inclusion and attempt to acknowledge the disproportionate vulnerability, emerging research suggests that such recognition remains superficial, with limited translation into rights-based or livelihood-centred interventions (Ziervogel, 2020).

Through an examination of first-generation CAPs from Mumbai, Bengaluru and Chennai, and emerging implementation efforts, this article calls for an India-specific climate action framework that centres informality, equity and justice; strengthens decentralisation; and positions urban local bodies (ULBs) as leaders of inclusive climate governance. Without such a shift, CAPs risk reproducing exclusion rather than advancing just and resilient urban futures.

Literature Review

Urban climate action¹ has been shaped by technocratic frameworks—such as the IPCC risk framework, Climate Risk and Vulnerability Assessments (CRVA), Disaster Risk Reduction approaches aligned with the Sendai Framework for Disaster Risk Reduction, urban climate risk modelling tools used by networks like C40 Cities and composite climate vulnerability or resilience indices—that conceptualise climate risk as a function of hazard, exposure and vulnerability (Unnikrishnan & Nagendra, 2021; Ziervogel, 2020). These approaches have informed climate action across cities by prioritising spatial mapping, infrastructure-led solutions and measurable indicators such as flood zones, heat indices and emissions inventories. While such frameworks provide scientific credibility, they tend to privilege technological interventions over social and political dimensions of vulnerability (Dodman et al., 2019; Pathak & Mahadevia, 2018). Studies show that vulnerability is not simply a product of environmental exposure but socially produced through insecure tenure, inadequate services, exclusion from planning processes and weak legal protections (Dodman et al., 2019; Satterthwaite et al., 2020). Informal settlements and informal workers remain underrepresented in official datasets and long-term planning, despite facing compounded risks related to housing, livelihoods, health and mobility (Sverdlik et al., 2024; Unni & Sinha, 2025).

The concept of informality has shifted from being understood as a residual or illegal sector outside formal governance to a mode of urbanisation produced through state practices, selective legal enforcement and planning regimes that differentiate between populations (McFarlane, 2012; Porter et al., 2011; Roy, 2009). Governments often tolerate elite land-use violations while criminalising informal settlements and livelihoods of the urban poor, reinforcing spatial injustice (Bhan, 2009; Burte & Kamath, 2023; Roy, 2009). Informality thus emerges not merely as a site of vulnerability but as constituted through land regulation, labour precarity and governance practices (Burte & Kamath, 2023; Pathak & Mahadevia, 2018). When framed as a technical or planning failure, climate interventions risk reproducing dispossession through eviction, relocation or rights-deficient formalisation (Porter et al., 2011; Tucker & Anantharaman, 2020).

CAPs have gained prominence globally as city-led instruments aimed at accelerating climate mitigation and adaptation (Aboagye & Sharifi, 2024; Singh et al., 2021). In India, they represent an important institutional shift, enabling cities to articulate climate goals, develop emissions inventories and identify sectoral actions (Unnikrishnan & Nagendra, 2021). However, CAPs lack statutory backing and remain weakly integrated with master plans and urban development frameworks (Kumar & Naik, 2019). Existing evaluations of CAPs in India have primarily focused on institutional capacity, financing constraints and the absence of statutory backing (Aboagye & Sharifi, 2024; Kumar & Naik, 2019; Unnikrishnan & Nagendra, 2021). Although CAPs reference inclusivity of vulnerable groups, studies show that inclusion remains symbolic or procedural (Unnikrishnan & Nagendra, 2021; Ziervogel, 2020). Participation is mediated through consultants, technical experts and civil society organisations. Increasingly, it is also noted that climate risk mapping has been used to designate informal settlements as ‘untenable’, legitimising relocation and displacement under the guise of resilience (Aboagye & Sharifi, 2024; Ziervogel, 2020).

While existing literature critiques the institutional, financial and participatory constraints of CAPs, it partly neglects how informality is delineated within climate planning in India. This failure to recognise informality as central to climate resilience in Southern cities remains a critical gap in urban climate governance. Emerging work on community-led climate action and counter-planning challenges these limitations by positioning communities as agents of change rather than passive beneficiaries, while revealing climate-related vulnerabilities overlooked by existing planning frameworks (Boyd & Juhola, 2014; Dodman et al., 2019; Randolph, 2017; Sverdlik et al., 2024; Unni & Sinha, 2025).

Methodology

This study adopts a qualitative research design to examine how informality, vulnerability and inclusion are framed within urban climate governance. CAPs are analysed as planning texts that reflect understandings of climate priorities and governance. The analysis focuses on CAPs from Mumbai, Bengaluru and Chennai, selected as early adopters of city-level climate planning whose approaches may influence emerging urban climate governance practices in India.

A textual analysis of the three CAPs was conducted to assess how informal settlements and informal workers are identified, categorised and prioritised. The analysis is organised around three key interrelated dimensions: (a) the structure and framing of plans, (b) participation and process for preparation and (c) the nature of sectoral actions proposed for vulnerable groups. It examines how vulnerabilities related to settlements, livelihoods and working conditions are articulated, and how inclusion is operationalised across sectors. To move beyond a text-based reading of CAPs, the study draws on semi-structured key informant interviews (KIIs) with five practitioners involved in CAP implementation at national and city levels, including actors from government advisory roles, technical partners and civil society organisations (CSO). These interviews examine post-drafting trajectories of CAPs, focusing on institutionalisation, implementation dynamics and inclusion in practice. The insights from interviews are triangulated with a review of publicly available implementation-related materials such as municipal notifications, budget documents, institutional orders, programme reports and progress updates from websites. The study also examines select Community-CAPs as forms of practice-based ‘counter-planning’ emerging from informal settlements (Randolph, 2017), to bring out alternative approaches to risk identification, prioritisation and engagement with urban governance.

City Climate Action Plans of Mumbai, Bengaluru and Chennai

CAPs evolved from voluntary, mitigation-focused initiatives into structured transition frameworks aligned with the Paris Agreement, integrating mitigation, adaptation and governance.² Early efforts prioritised emissions inventories and energy efficiency, while the mid-2000s saw increasing standardisation through global networks.³ This evolution was institutionalised through global city networks, most notably C40, which standardised climate action planning through its CAP framework (C40 Cities, 2020). Subsequent implementation learning informed the Cities Climate Transition Framework (CCTF), which shifts emphasis from plan preparation to delivery, strengthening governance integration, sectoral strategies, equity and monitoring (C40 Cities, 2023). Between 2020 and 2025, the C40 Cities framework has demonstrated a positive evolution, from a component-based planning guide to a more implementation-oriented and governance-centred approach. The updated framework places greater emphasis on delivery, mainstreaming climate action across city governance, development of sectoral strategies, and strengthening of monitoring, evaluation, reporting and learning systems. It also reflects a more explicit engagement with equity, vulnerable communities, inclusionary decision-making and the role of city powers in enabling action. However, despite these advances, the framework continues to rely on principle-based guidance that presupposes institutional coherence, data availability and governance capacity. These underlying assumptions limit its applicability in many Southern urban contexts, especially Indian cities, where governance fragmentation, informality, vast numbers of vulnerable communities and uneven capacities of city governments vis-à-vis governance structures shape both the possibilities and constraints of climate action. As a result, CAP and CCTF frameworks remain insufficiently grounded in Southern urban realities.

India’s city-level climate action has evolved within a multi-scalar policy architecture shaped by national, state and transnational influences. At the national level, the National Action Plan on Climate Change, 2008, framed climate action around co-benefits and climate justice, while State Action Plans on Climate Change (SAPCCs),⁴ initiated from 2009, prioritised adaptation and low-carbon development, albeit with limited urban specificity and focus (Government of India, 2008). A coordinated state-led push for city-scale climate planning emerged only in 2019 with the launch of the Climate Smart Cities Assessment Framework (CSCAF) (NIUA, 2023).⁵ India’s other national-level policy frameworks include the Nationally Determined Contribution (NDC) 1.0 and 2.0 versions—both mandated to focus on mitigation—that have minimal references to the urban and predictably focus on sectors of energy, buildings, transport and other emission-centric fields.⁶ India has also not formulated a National Adaptation Plan for submission to the United Nations Framework Convention on Climate Change (UNFCCC). At a governance level, most climate action is focused on international-level reporting, with national-level action led by the Ministry of Environment, Forest and Climate Change, with decentralisation to states through SAPCCs. The National Disaster Management Authority leads the disaster response mechanisms across geographies, supported by State Disaster Management Authorities. The Ministry of Housing and Urban Affairs, leading urban policy imagination, though gradually, has opened to climate action, visible through incubating the CSCAF and other climate mainstreaming at the national level, but it still has not taken decisive measures for climate action at the city level. As a result, CAPs remain non-statutory, technocratic and weakly integrated with master plans,⁷ often prioritising short-term projects over transformative, people-centred climate action. From 2020 onwards, this trajectory translated into formal CAP adoption, with Mumbai leading the development of a Paris Agreement–aligned plan, followed by Bengaluru and Chennai, using C40’s standardised methodologies for emissions inventories, climate risk assessments and scenario modelling.

Overview of CAPs: Goals, Structure, Focus Areas and Actions

The CAPs of Mumbai, Bengaluru and Chennai represent strong strides by Indian cities to localise and institutionalise climate action in line with global goals. Mumbai launched India’s first Climate Action Plan in 2022, aiming for net zero by 2050 (Brihanmumbai Municipal Corporation [BMC], 2022). Bengaluru’s 2023 BCAP targets carbon neutrality and resilience (Bruhat Bengaluru Mahanagara Palike [BBMP], 2023), while Chennai’s 2022 draft CAP envisions a proactive, climate-resilient city (Greater Chennai Corporation [GCC], 2022).

Each plan begins with a vision and goals for carbon neutrality and climate resilience, with a strong ‘equity’ perspective,⁸ followed by city profiling (including emissions inventories and vulnerability assessments). This is followed by outlining sectoral interventions across key areas such as energy, transport, waste, water, air quality, biodiversity and disaster management, detailing actions by priority and timelines. The plans do emphasise equity and inclusivity, mentioning some of the vulnerable groups, and include sections towards the end on governance, financing and monitoring. All plans mention Inclusive Climate Action Planning guidelines (C40 Cities, 2020) and the CAP framework of C40 as a principle for inclusion and refer to the Sustainable Development Goals (SDGs)—specifically SDG 11⁹—the one focusing on cities and climate action.

The CAPs share overarching objectives of advancing climate resilience and achieving net-zero emissions through structured, sector-focused approaches. Each, however, exhibits distinct emphases (Table 1). Overall, these plans and the sectoral focus reveal a mitigation bias, with energy, transport, water and waste consistently prioritised. In contrast, vulnerable communities and other aspects related to communities/populations—despite their centrality to climate vulnerability—remain negligibly addressed as sectoral focus areas, except for the Chennai CAP that has a specific sector for vulnerable populations (highlighted in Table 1).

Table 1.

Overview of Climate Action Plans and Sectoral Focus Areas Across Cities.

City	City Climate Action Plan	Key Focus Areas/Sectors
Mumbai	Mumbai Climate Action Plan (MCAP) 2022	1. Energy and buildings 2. Sustainable mobility 3. Waste management 4. Urban greening and biodiversity 5. Air quality 6. Urban flooding and water resource management
Bengaluru	Bengaluru Climate Action and Resilience Plan (BCAP) 2023	1. Energy and buildings 2. Transportation 3. Solid waste 4. Air quality 5. Water, wastewater and stormwater 6. Urban planning, greening and biodiversity 7. Disaster management
Chennai	Chennai Climate Action Plan (CCAP) 2022 (Draft)	1. Electrical grid and renewable energy 2. Building energy 3. Transport 4. Waste management 5. Urban floods and water scarcity 6. Vulnerable populations and health

The CAPs of Mumbai, Bengaluru and Chennai further outline sectoral strategies with multiple tracks and actions: MCAP, covering 6 sectors, includes 190 actions; BCAP, covering 7 sectors, lists 267 actions; and CCAP, spanning six sectors, outlines 183 actions.¹⁰

Participation in the Preparation of Climate Action Plans

The CAPs were developed through multi-stakeholder consultations aimed at integrating global climate frameworks with local realities. However, the depth and inclusivity of participation have varied significantly and were limited due to its structure. The CAPs were initiated through partnerships of ULBs and technical agencies, with local presence supported by international networks.¹¹ CAP preparation typically begins with a diagnostic phase involving greenhouse gas inventories, CRVAs and sectoral baselining. These technically intensive processes are largely led by external technical agencies, with limited in-house capacity within ULBs shaping their reliance on external expertise.

The MCAP process involved three consultation rounds: expert inputs from civil society and research groups across key sectors, inter-departmental coordination within the city government and ward-level public outreach. Over 300 citizens submitted online feedback, mostly on adaptation issues like flooding and air pollution. BCAP is reported to have adopted a three-tier consultation model: engaging over 40 departments, holding expert webinars and conducting ward-level public meetings using bilingual toolkits. CCAP reportedly was the broadest in nature on participation, with over 200 stakeholder meetings conducted, including a Climate Change Risk Assessment workshop focused on vulnerable communities.¹²

At the core of CAP preparation are structured engagements with municipal departments, parastatal bodies and state-level agencies responsible for key sectors such as transport, water, energy, waste and housing. These interactions are critical for data access, validation of proposed actions and aligning climate priorities with existing mandates. Beyond government actors, CAP processes have incorporated CSO, academic institutions and thematic experts through workshops, focus group discussions and public consultations, broadening the scope of plans to include concerns such as heat stress, informal livelihoods, housing precarity and service access. However, participation by communities themselves—particularly informal settlements, workers and marginalised groups—has largely been mediated through CSOs rather than direct representation, constrained by time, resources and the technical framing of climate discourse. Limited public consultations, when conducted, have remained largely consultative, aimed at gathering inputs and building public legitimacy rather than enabling co-productive decision-making. Notably, these consultative processes are voluntary and largely driven by technical support partners,¹³ facilitating expert engagement, coordination with state agencies and online feedback mechanisms, in line with the participatory criteria outlined in C40’s CAP framework. The COVID-19 pandemic further shaped participation, pushing many cities towards online consultations, which expanded expert reach but limited grassroots engagement. Online feedback mechanisms were also in place in Mumbai and Chennai, but likely constrained participation due to digital access barriers. Urban poor communities and workers were presumably at a particular disadvantage for a host of reasons: inequitable access to digital tools, language barrier and lack of engagement with climate framing.

The planning process, with its open consultative approach, provided grounding for technical support agencies working on CAPs to initiate exchanges and build relations with other stakeholders, especially departments at the state and city levels, but limited systematic meaningful engagement with diverse vulnerable communities, including informal workers, informal settlement residents, unions and grassroots organisations.

Inclusion of Vulnerable Groups

The CAPs of Mumbai, Bengaluru and Chennai emphasise inclusion and equity, aiming to reduce climate risks while addressing poverty. An analysis of the three CAPs identifies only 18 vulnerable groups altogether, as listed in Table 2. BCAP adopts the better inclusion framework, recognising a wide spectrum of vulnerable groups across identities, occupations and settlement types. It is the only plan to explicitly include LGBTQIA+ individuals, gig workers and Scheduled Caste/Scheduled Tribe communities, indicating a deeper understanding of intersectional vulnerabilities. MCAP and CCAP largely focus on traditional vulnerable categories such as women, children, the elderly, urban poor and informal workers in general, with both additionally noting fisherfolk and Mumbai noting traffic police as well. Notably, both Chennai and Mumbai omit gig workers, street vendors and LGBTQIA+ persons, highlighting gaps in recognising vulnerabilities. In addition, many sectors of informal workers are omitted from all three CAPs, noteworthy amongst them being the women-dominated sectors of home-based work and domestic work.

Table 2.

Inclusion of Vulnerable Groups Across Climate Action Plans of Mumbai, Bengaluru and Chennai.

Vulnerable Group	Mumbai (MCAP)	Bengaluru (BCAP)	Chennai (CCAP)
Women	✓	✓	✓
Children	✓	✓	✓
Elderly	✓	✓	✓
Persons with Disabilities	✓	✓	✓
LGBTQ+^* Individuals	✕	✓	✕
Low-Income Communities/Urban Poor	✓	✓	✕
Slum Dwellers/Informal Settlements	✓	✓	✓
Houseless Populations	✕	✓	✕
Migrant Workers/Internal Migrants	✓	✓	✕
Informal Workers (General)	✓	✓	✓
Street Vendors	✕	✓	✕
Ragpickers	✓	✓	✕
Waste Workers (General Category)	✓	✓	✕
Construction Labourers/Workers	✓	✓	✕
Gig Economy Workers	✕	✓	✕
Scheduled Castes and Tribes	✕	✓	✕
Fisherfolk Population	✓	✕	✓
Traffic Police	✓	✕	✕

Notes: *The Bengaluru Climate Action Plan identified only ‘LGBTQ+’ communities. In this article, we adopt the more widely accepted and contemporary convention ‘LGBTQIA+’, which is inclusive of lesbian, gay, bisexual, transgender, queer, intersex, asexual and other non-heteronormative and gender-diverse identities.

Included ✓ Not included ✕

CAPs visibly acknowledge the vulnerabilities of informal settlements, slum residents and informal workers and articulate intentions to equitably distribute co-benefits such as thermal comfort, clean energy, water, safer mobility and improved health and livelihoods. Vulnerable groups—including women, children, older persons and persons with disabilities—are frequently identified in vulnerability assessments and baselines but receive limited attention in proposed actions. While this recognition is a positive step, it is constrained by weak data representation and a limited understanding of the diversity of vulnerabilities shaped by informality, spatial location, lack of social protection and irregular incomes. As a result, these groups are subsumed under broad categories of ‘urban poor’ or ‘slum populations’, restricting the scope of action. Vulnerability is thus narrowly framed in CAPs, largely through spatial risk exposure rather than lived and structural conditions. Had CAPs employed a more rounded framework of vulnerability—integrating residential, occupational, social and climate risks—they would have offered a more inclusive and effective approach to climate resilience (Ministry of Housing and Urban Poverty Alleviation [MoHUPA], 2013).

Assessing Actions Regarding Informal Settlements in CAPs

Slums find mention across the CAPs. MCAP identifies that 42 per cent of residents live in slums, facing heightened exposure to flooding, landslides, heatwaves and air pollution. BCAP identifies over 250 notified slums and several thousand undocumented ones in peripheral, underserved areas, with 18.6 per cent of the population in slums, many in ‘untenable locations’ like riverbanks and floodplains. The CCAP likewise proposes a re-survey and relocation of 260,000 lakh residents from high flood-risk zones. The CAPs propose a comprehensive suite of actions across sectors—housing, health, water and sanitation, waste management, energy, livelihoods and governance—to enhance climate resilience and equity (Table 3).

Table 3.

Interventions in Slums/Informal Settlements Across Climate Action Plans of Mumbai, Bengaluru and Chennai.

City CAP	All Interventions for Slums/Informal Settlements in Climate Action Plans
MCAP	• Retrofit informal housing with LEDs, insulation, cooling and legal recognition • Mandate heat-resistant roofs/walls in new EWS housing • Gradual in-situ rehab from hazard-prone areas with risk mapping • 150 LPCD water for all, including slums • Slum sewerage to end manual scavenging • LPG-based community kitchens in slums • Ward-level health camps for slum/migrant groups • Zero-waste slum pilots for waste management • Rainwater harvesting, solar and passive cooling in low-income housing • Energy cell to coordinate building sector work for the poor
BCAP	• Affordable housing for all urban poor by 2050 near transit • Prioritise slums via vulnerability mapping • Climate-proof slums with retrofits, in-situ redevelopment and nature-based solutions • Relocate high-risk settlements to safer housing • Local disaster management cells • Subsidised reversible fans for cooling • Public/community toilets to end open defecation • Universal piped water, with slum priority • Waste picker licensing, ward-level mustering centres • Slum training on disaster and waste management • Participatory planning with informal residents
CCAP	• Rehab slums in floodplains/coastal zones via community-led process • Retrofit with cool roofs, insulation, reflective paint; SHG/microfinance support • Enforce ENS and revise codes for climate-resilient design • 100% resilient basic service access in slums by 2050 • Re-survey and relocate ~2.6 lakh from high flood-risk zones • Basti clinics for decentralised health in underserved areas • Early warnings and health campaigns via SHGs/local groups • Build 65,000 climate-resilient homes with World Bank/ADB • Target asbestos-roof homes for upgrades • Waste segregation and 100% collection by 2030 • Assess fisherfolk housing for sea-level rise risks

While CAPs begin by articulating the scale and demographics of slum vulnerability, their interventions reflect only a limited expansion of the climate agenda to include informal settlements. Proposed actions remain few and fragmented, largely centred on service provision and framed through co-benefits, with little commitment to structural change. By failing to centre tenure security and planning inclusion, these measures risk reproducing marginality, particularly where climate vulnerability is used to justify ‘relocation’ and ‘rehabilitation’ strategies most visible in the case of Chennai (Table 3). The deferral of even basic service provision through timelines extending to 2050 further underscores the limited transformative ambition of these plans vis-à-vis informal settlements.

Assessing Informal Worker Groups in CAPs

Informal workers constitute nearly 90 per cent of India’s labour force and contribute almost half of the national GDP (ILO, 2018), yet their treatment within CAPs remains uneven. While all three plans acknowledge informal workers, their inclusion is far thinner than that of informal settlements. Baselines and vulnerability assessments offer limited or no data on worker numbers, spatiality of informal work or gendered dimensions of labour.

MCAP mentions informal and low-income workers, who make up nearly 65 per cent of the city’s workforce. It highlights workers’ exposure to heat, flooding and pollution, proposing housing retrofits, clean-fuel kitchens, cooling subsidies and occupational health measures, with waste pickers prioritised for formalisation, and construction and transport workers for safety training. BCAP provides the most detailed framing, prioritising migrants, gig workers, pourakarmikas (waste workers), ragpickers, vendors and sanitation workers through measures focused on resilient housing, livelihood protection, cooling subsidies and green skills. CCAP identifies fewer worker categories but offers deeper profiling of fisherfolk and proposes interventions for safer housing, education and marine safety, but broader labour concerns remain underdeveloped. An analysis of CAPs shows uneven recognition of urban workers. Only 19 such categories are identified.¹⁴ Bengaluru’s plan is the most inclusive, referencing 13 worker groups, including street vendors, gig workers and sanitation workers. Mumbai identifies 11 groups, mostly in essential services, while Chennai mentions only 6, reflecting a limited understanding of occupational vulnerabilities. While the CAPs may demonstrate growing recognition of workers, there are not many specific measures/actions directed at these large groups or their livelihoods in CAPs. Most of the few proposed interventions focus on where workers live, in informal settlements and not on their work or where they work. Climate risks at worksites—markets, streets, construction sites and urban commons—remain largely unaddressed. This reveals a spatial and sectoral gap in planning, with livelihood vulnerabilities insufficiently integrated into climate adaptation strategies. The gap in addressing informal livelihood and gendered labour dimensions remains unresolved.

Assessing Actions for Informal Settlements and Worker Groups in CAPs

To assess how equity commitments translate into action, all proposed actions in the CAPs were analysed vis-à-vis informal settlements and workers (Table 4). MCAP includes 20 of 190, BCAP allocates 31 of 267, and CCAP allocates 28 of 183 actions for slum residents and workers. Despite being among the most numerous and climate-vulnerable urban populations in these cities, only 10–15 per cent of actions in each CAP target these groups. Moreover, it is to be noted that many are indirect co-benefits rather than focused interventions, and thus, the real figure may be much lower. This reveals a critical gap in the forefronting of the most vulnerable groups in inclusive climate planning.

Table 4.

Key Actions for Informal Settlements (Low-Income Settlements) and Worker Groups in Climate Action Plans.

City	Total Number of CAP Actions	Number of Actions Specific to Slums and Workers
Mumbai	190	20
Bengaluru	267	31
Chennai	183	28

Trajectories of Implementation of Climate Action Plans in Indian Cities

This section examines the post-drafting phase of CAPs, focusing on early implementation efforts and key interventions aimed at institutionalising climate action within city governments. Across the three cities, CAPs signal a shift towards decentralised climate governance by recognising ward committees and neighbourhood institutions as key sites of action. Bengaluru advances this most explicitly through mandatory ward-level climate plans co-produced by ward committees and inclusive of vulnerable groups. Chennai similarly envisages deeper devolution via ward committees and area sabhas linked to city-level coordination. Mumbai, by contrast, limits participation to ward- and zonal-level consultations led by assistant commissioners. While these approaches acknowledge the need for decentralisation, pathways for meaningful decision-making by informal settlements and workers remain weak. CAPs also signal a turn towards diversified climate financing through emerging climate budgeting mechanisms across all three cities. This section draws on KIIs with practitioners directly involved in the preparation and implementation of CAPs in the selected cities, as well as policy practitioners engaged with CAP processes in other Indian cities.

Implementing CAPs: Institutionalising Climate Cells

A common institutional response across cities has been the establishment of climate cells, though their mandates and effectiveness varied significantly across contexts. In Mumbai, the CAP process revealed the near absence of an environmental governance apparatus within the municipal corporation, where the ‘environment department’ functioned primarily as a compliance-oriented reporting unit under solid waste management, with no planning capacity. CAP efforts, therefore, focused on repurposing this marginal unit into a coordinating node rather than a siloed department, resulting in a hybrid structure comprising a small number of sanctioned posts under senior municipal leadership, supported by technical experts and thematic fellows.¹⁵ Bengaluru followed a different trajectory, enabled by strong bureaucratic leadership and the consolidation of climate-relevant functions—lakes, parks, horticulture and environment—under a single Indian Administrative Services officer.¹⁶ This reduced inter-departmental friction and reframed climate action as an organising umbrella for core civic functions rather than an external agenda. Chennai’s approach has been more state-led, anchored in the Tamil Nadu Climate Cell¹⁷ and the Green Climate Company,¹⁸ with the municipal corporation positioned largely as an implementation partner, focused on rapid, detailed project report preparation over long-term institutional reform. Across all three cities, fellows and intermediary support actors played a critical binding role, mediating between political leadership, state departments and municipal bureaucracies to stabilise and seed climate cells, particularly in Mumbai and Bengaluru.

Bengaluru’s Climate Action Cell, established in early 2024 under the Bruhat Bengaluru Mahanagara Palike, has been the most active, translating the BCAP into ongoing initiatives across sectors, including water resilience, waste, energy, greening and adaptation. Operating with multi-stakeholder representation and supported by digital outreach and stakeholder convenings, the cell has coordinated awareness campaigns, participatory data collection efforts (e.g., open well mapping) and city-wide Climate Action Clubs in schools and institutions. Its persistent activity expands BCAP’s reach into community and institutional engagement, making it one of the dynamic urban climate governance mechanisms (BBMP, 2023).

Climate Budgeting and Incrementalism

The other significant post-CAP institutional innovation has been climate budgeting. This was led by Mumbai in 2022. Rather than creating a standalone climate budget, the process functioned as a climate sensitisation and budget tagging mechanism embedded within the municipal budget cycle. Beginning with a pilot in the solid waste department, climate tagging expanded to nearly 80 per cent of municipal departments in the course of two years (WRI India, 2024). The finance department institutionalised the practice through templates and circulars, requiring departments to explicitly link budget allocations to CAP actions. This mechanism reframed climate action as a fiscal question—‘What are you already doing that contributes to climate outcomes?’—thereby reducing departmental resistance and enabling incremental uptake. Bengaluru adopted a similar but more decentralised approach, allocating ward-level climate budgets (Citizen Matters, 2024). The symbolic importance of recognising climate action as a legitimate budgetary category was substantial. Chennai’s experience suggests that adaptation-oriented expenditures—particularly large-scale stormwater drainage investments that were politically also very popular—have been easier to mainstream fiscally due to their immediacy and visibility, even when not explicitly labelled as climate projects. These experiences underline a key insight: institutionalisation in the case of CAPs through the re-labelling and reframing of existing infrastructure investments— drainage, parks, lakes and public health facilities—through a climate lens, rather than through entirely new funding streams.

Politics and Public Discourse

CAP institutionalisation has also been contingent on the political context. In Mumbai, early momentum was closely tied to a political dispensation that foregrounded environment and nature as part of its public political identity. As political power shifted, it did lead to a slowing of actions, but did not result in institutional collapse, also partly because of the popularity of climate action in public discourse. Projects sanctioned earlier continued incrementally, and visible on-ground interventions as nature-based solutions (NbS)—urban forests, river-edge projects and eco-STPs—generated new legitimacy that allowed climate action to re-enter political discourse in less ideological forms (WRI India, 2025). Across cities, practitioners emphasised incrementalism as a strategy rather than a failure. Micro-projects, pilots and phased reforms allowed institutions to learn, adapt and build confidence. So, a supporting political context surely aids climate action, but once institutionalised, incremental, smaller-scale actions are equally powerful. The presence of an increasingly sensitised bureaucracy is also important to climate action. As one reflection notes, ‘incremental change is transformative’ in bureaucratic contexts characterised by entrenched interests and fragmented authority.

Tactical Inclusion Through Sectoral Embedding

A notable feature of CAP institutionalisation in Indian cities has been the attempted tactical embedding of inclusion within sectoral strategies rather than treating equity as a standalone theme. Led by the technical support agencies in the implementation phase, also with the loose network of supporting CSOs, this approach was particularly evident in Mumbai and Bengaluru in different ways. The CAP reports and documents admitted could not focus much on vulnerable communities, partly also recognising that such framing often triggers bureaucratic resistance rooted in narratives of illegality, especially in the case of informal settlements and livelihoods. In this phase, inclusion was attempted through operationalisation of CAPs.

In Mumbai, it meant that the implementation aimed to shift focus from mitigation-heavy electric vehicle narratives towards ‘affordability, pedestrian infrastructure, and public transport’. In flood management, reframing the sector as ‘flood risk and water resource management’ created space to address everyday service deficits in informal settlements as core resilience issues. In waste management, inputs from practitioners working with informal waste pickers linked climate mitigation to livelihoods and social protection. Bengaluru’s post-CAP phase has pushed inclusion further through the decentralisation of ward-level climate action pilots and the creation of thematic working groups. The thematic working groups constituted government departments and CSOs with a long history of proven expertise and work in communities that were onboarded to actualise the CAP implementation. These initiatives respond to the scalar limitations of city-level plans by translating climate priorities into neighbourhood-scale actions—cool roofs, zero waste and flood mitigation—where engagement with informal workers and resident groups becomes more feasible. Despite these small but promising advances, inclusion remains mediated largely through CSOs rather than structurally embedded mandates.

The CAP experience in Indian cities suggests that urban climate action has catalysed an evolving institutional ecosystem rather than a linear implementation pathway. Climate cells, budgeting practices, ward-level pilots, thematic working groups and state-level climate units together constitute an emerging ‘hybrid governance’ architecture for implementing CAPs. This architecture does not replace statutory planning but operates alongside it and around it, enabling coordination across sectors and scales that conventional land-use planning cannot easily accommodate. CAPs have tried to address everyday urban issues—heat, flooding and waste, mobility—by framing them as matters of climate risk, urgency and collective responsibility. Their institutional impact lies less in statutory authority and more in their capacity to reorient bureaucratic routines and cross department fiscal logics, shifting public and possibly political narratives through small, successful micro-projects; all the while including vulnerable communities through innovative governance mechanisms.

Counter-planning by Communities: A Case Study from Mumbai

City CAPs are non-statutory and flexible, unlike land-use plans anchored in property regimes and legal status. This flexibility can enable ground-up planning with community-based organisations, as discussed through the following example.

Whilst CAPs are evolving at the city level, many Community-CAPs are emerging from the ground through collaborations between NGOs¹⁹ and people’s collectives.²⁰ This unfolds through four interconnected steps. First, at the city scale, Climate Hazard Mapping identifies the exposure of informal settlements—frequently absent from official datasets—to hazards such as flooding, heat stress and air pollution, enabling the classification of areas with overlapping risks as climate hotspots (Goswami & Parmar, 2024). Second, Rapid Assessments translate this spatial diagnosis to the settlement level by examining sensitivity and adaptive capacity, including insecure tenure, service deficits, livelihood precarity and disaster preparedness. Third, a community-led Vulnerability Assessment employs geo-tagging, interviews and focus group discussions facilitated by local youth to document differentiated, occupation-specific risks faced by a varied set of workers, with a special focus on gendered dimensions. Fourth, these findings inform a Community-CAP that situates climate risk within broader social, infrastructural and governance constraints, prioritising settlement-wide and collective interventions over individualised or technocratic responses (Figure 1).

Figure 1.

Source: YUVA.

Unlike city-level CAPs, which treat climate risk in abstraction and offer generalised solutions, the Community-CAP is rooted in local land politics and identifies priority actions across immediate, short- and long-term timeframes along with more local stakeholders, such as Mohalla Samitis,²¹ municipal departments and ward-level officials. In Ambojwadi,²² for example, the absence of a stormwater drainage system was prioritised. With sustained engagement, the community secured municipal funding for drainage construction, demonstrating how people-led plans can influence formal governance (Nuggehalli & Parmar, 2025) (Figures 2 and 3).

Figure 2.

Source: YUVA.

Figure 3.

Source: YUVA.

Alongside, residents co-financed a greening initiative to address heat stress, showcasing the potential of hybrid state–community financing. This illustrates the transformative capacity of micro-adaptations when grounded in community ownership and dialogue with municipal authorities. A key learning was that reframing basic service provision through a Community-CAP enabled municipal prioritisation and funding, which was previously inaccessible. Across cities, communities—often with civil society support, under the wider umbrella of CAPs—are gradually translating climate risks into practical action (The Indian Express, 2025; The Times of India, 2026). In this framing, co-production functions not simply as a methodological choice but as a political intervention that reorients climate governance towards justice by embedding climate action within lived realities, everyday negotiations and claims-making by the urban poor (Mohan & Muraleedharan, 2024).

Discussion

Despite their rapid proliferation, CAPs in Indian cities remain constrained by entrenched structural, institutional and political limitations. As largely strategic, non-statutory instruments, they frame climate risk as a governance concern without creating enforceable obligations. Core questions of land, justice and inequality remain marginal, and CAPs rarely interrogate dominant planning or governance frameworks. Even as climate narratives project catastrophic futures—such as sea-level rise in cities like Mumbai or Kolkata—these risks are routinely sidelined, while potentially maladaptive large-scale infrastructure projects, including coastal roads, escape critique. Climate governance remains highly centralised, with limited decentralisation to states and no clear mandate for urban governments. ULBs therefore face persistent mismatches between responsibility, authority and capacity, tasked with delivering mitigation and resilience despite limited control over key sectors. Adaptation is frequently displaced to disaster management authorities operating outside municipal planning systems. Even in these restricted conditions, CAPs and their early years reveal interesting possibilities of influencing urban climate action from outside, and key lessons for future implementation.

The first phase of CAPs is rooted in global climate action frameworks that, while well intentioned, are largely designed for cities in the global North. These principle-based guidance frameworks remain insufficiently grounded in the socio-spatial, institutional and political realities of Southern cities. Although they have increased the visibility of informal communities as ‘vulnerable’, they have not enabled recognition of differentiated vulnerabilities or the heterogeneity of communities.

This patchy recognition stems from a misalignment between community-prioritised adaptive needs and mitigation-heavy planning templates that privilege quantifiable and bankable interventions. Weak participatory mechanisms and limited ULB capacities further mean that participation in CAPs—which is voluntary and driven by technical agencies—is reliant on mediated civil society consultations, leaving many climate-vulnerable communities without the access, language or framing capacity to engage meaningfully in these processes.

While the vulnerability of settlements and livelihoods is increasingly acknowledged in CAP assessments and baselines, this recognition rarely translates into implementable actions. Where some settlement-level interventions are proposed, they remain limited in scope, with CAPs largely neglecting livelihoods, working conditions, social protection and just transition. As a result, informal settlements and workers are rendered as abstract ‘vulnerable’ groups, detached from lived risks, livelihood realities and everyday concerns.

Across CAPs, informal settlements are frequently framed as ‘untenable’ or ‘uninhabitable’, normalising relocation as a climate response and converging with long-standing agendas of slum clearance. This constitutes—we posit—dispossession by vulnerability, in which climate risk labels legitimise displacement, deepening insecurity by treating communities as problems to be moved rather than rights-bearing residents to be protected.

Despite these challenges and exclusions, CAPs also open limited yet important windows for transformative change. The drafting process has functioned as an initial platform for convening multiple state- and city-level departments around climate action. More significantly, the implementation phase holds greater transformative potential, as ‘hybrid governance’ arrangements—such as climate action cells, climate budgeting and the decentralisation of climate planning—are institutionalised. Over time, they may influence our current redundant urban governance frameworks, enable meaningful decentralisation and embed climate action within urban governance.

Counterintuitively, CAPs may open limited, localised spaces for engaging with informality through a climate action lens—spaces that statutory planning and existing urban governance frameworks struggle to accommodate. While current CAP frameworks and their largely depoliticised, technocratic modes of engagement with the most climate-affected communities remain inadequate, early implementation phases have begun to create narrow but significant entry points through ‘tactical inclusion’. These include small-scale pilot interventions in Mumbai, the inclusion of informal settlements and workers within ward-level thematic planning groups in Bengaluru or opportunities that facilitate counter-planning and co-production through Community-CAPs. Through these emerging innovative practices, CAPs also hold the potential to demonstrate adaptation actions—as opposed to more favourable mitigation efforts—for diverse communities, generating a repertoire of adaptation-oriented actions for Indian cities that can be replicated at the national level.

Conclusion

As CAPs gain traction across Indian cities, there is a pressing need for an India-specific CAP framework grounded in lessons from cities experimenting with climate action. Such a framework must be context-sensitive, accounting for differences in size, geographies and capacities, while clearly conceptualising vulnerability and informality and making equity and justice of communities a key focus. Failure to centre vulnerable populations risks reproducing exclusion and marginalising those most exposed to climate impacts through ‘dispossession by vulnerability’.

At present, CAPs remain voluntary instruments. However, as climate impacts intensify and climate action is increasingly mainstreamed across urban sectors, the expansion of schemes and programmes across climate and urban ministries appears inevitable. It is for that eventuality that the present experiments with CAPs could prove valuable. These can translate the emerging ‘hybrid governance’ mechanisms with ‘tactical inclusion’ into alternative urban climate action through decentralised approaches that strengthen community participation and position ULBs as leaders rather than implementers, while continuing to facilitate counter-planning and co-production of Community-CAPs, and gradually mainstreaming decentralised climate action and reshaping political sensibilities.

In this context, communities, worker collectives and CSO must actively articulate CAPs and influence their trajectory, ensuring that climate governance does not remain technocratic and exclusionary. CAPs hold the potential to advance urban climate action from the ground up, challenging India’s historically centralised climate policy architecture. Without such a shift, we risk entrenching exclusion rather than enabling just, equitable and sustainable urban futures.

Footnotes

Declaration of Conflicting Interests

The authors declared no potential conflicts of interest with respect to the research, authorship and/or publication of this article.

Funding

The authors received no financial support for the research, authorship and/or publication of this article.

Notes

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