NIC0025

 

Written evidence submitted by techUK

 

techUK

techUK is the trade association which brings together people, companies, and organisations to realise the positive outcomes of what digital technology can achieve. With over 800 members (the majority of which are SMEs (Small and Medium Enterprises)) across the UK (United Kingdom), techUK creates a network for innovation and collaboration across business, government, and stakeholders to provide a better future for people, society, the economy, and the planet. 

 

Executive Summary

The JCNSS has called for evidence to the inquiry into the climate resilience of Critical National Infrastructure. This asks stakeholders to give their views on the following 7 topics.

techUK will collate responses from several stakeholder groups which who may be invested in the business continuity aspect of climate resilience building.

 

Topics:

 

1. Key vulnerabilities and levels of preparedness of UK CNI to extreme weather events and other effects of climate change, including:

Overview:

We expect climate change to drive and increase in:

  1. Occurrences of windstorms
  2. Droughts and reduced water supply
  3. Heat waves
  4. Wildfires
  5. Floods

Compounding effects include:

  1. Risk to life
  2. Services blackout
  3. Staff shortages
  4. Total Black Start scenario
  5. Supply chain delays or failure in relation to perishable goods.

Interdependencies:

  1. Reliance of telecoms on energy IS
  2. Reliance of most CNI on some form of telecoms
  3. Emergency service reliance on energy and telecoms

 

1.1 The Climate Change Committee has determined that UK telecommunications infrastructure is at risk from all types of flooding, high winds, and lightning strikes. In 2018, the telecoms sector completed its remaining programme[1] of installing permanent flood defences, with regulator Ofcom revising security and resilience guidance to include specific flood risk and other climate related requirements.

1.2 The most serious climate-related issue facing communications resilience is interacting risks (CCRA risk In1)[2]. CNI is a system of systems, with communications underpinning how many other infrastructure systems operate, and power resilience is a reciprocal risk for communications networks. Telecoms engineers may be unable to access sites if transport routes are impacted, or high winds bringing down power lines impacting physical infrastructure. Recent scenarios for the inquiry to consider include the impact of Storm Arwen in the north of the UK, where reliable mobile network coverage was impacted by a loss of power supply, and some consumers with VOIP services were unable to use their landlines.[3]

 

1.3 Regarding supply chain vulnerabilities, the government has undertaken a comprehensive review of the supply arrangements for the UK’s communications sector, which identified the need to manage and mitigate risks from high-risk vendors, introduce a new robust security framework for telecoms, and create a more diverse and competitive supply base for telecoms networks.[4] The government’s 5G Supply Chain Diversification Strategy[5] sets out further plans to diversify the global telecoms supply market, focussing on three key areas of activity: 

 

1.4 techUK’s view is that the strategy to diversify the telecoms supply chain will help to mitigate part of the supply chain vulnerabilities in the longer term, but further steps need to be taken to accelerate mitigation. Semi-conductor supply shortages have been a well-known issue throughout the pandemic; however, these are short term supply issues resulting from huge demand and we anticipate this to return to normal shortly. techUK notes international efforts to address these issues but would caution against short term interventions.

 

1.5 The transition to fibre broadband from copper creates new issues for the resilience of telecommunications, with fibre being reliant on the continuation of the power network to function. “Whole-system” planning would build resilience in this aspect. It is the industries view that placing the cost of resilience on telecoms providers would be an unreasonable burden due to the heterogeneity of coverage by area, and the reliance on telecoms by other sectors who are outside of the CNI scope.

 

1.6 On-site power storage solutions are problematic for resilience building at present for several reasons. In the case of battery use at mobile cell sites, power resilience is inherently limited and will vary between sites. They do have their place in the interim period before a better solution is devised.

1.61 The use of on-site fuel generators is also an issue as fuel cannot be stored indefinitely, and their presence/use may have implications for the meeting of net zero targets for telecoms providers.

1.62 Battery packs for consumers in the case of a power outage comes with several issues: disruptive to the consumers living arrangements, environmentally damaging and ineffective for long-term power outages.

 

Data Centres

[risk overview set out in CRRA 3 chap 4 4.14.]

1.7 Data centre resilience is, similarly to telecoms, reliant on the resilience of the energy and road infrastructure for power and staff access. There are serious security and economic implications of poor resilience in the data centre community, however, techUK has recently published a detailed account of this which can be found here.

 

2. What might constitute an ‘acceptable’ level of resilience to climate change within UK CNI, both to near-term risks and longer-term uncertainties or ‘tipping points’, and the obstacles to achieving it.

 

2.1 New and emerging telecoms equipment used in the UK are specified to international design standards, therefore installing fibre optic cabling in UK networks that is designed to operate in global extremes of temperature, embeds resilience to climate change.

New and emerging telecoms network management techniques also mitigate risk. So, while 5G architecture (including network slicing, edge compute, densification and IoT) presents new elements of complexity in the UK market, the adoption of network virtualisation, data analytics, AI and Machine Learning, can help manage radio outages without causing significant disruption to services.

 

2.2 For telecoms providers there is some concern that the continued reliance on telecoms as a ‘network of last resort’ is problematic without the additional support from third parties to build so called “public good” resilience measures. Third parties could include the taxpayer, data software companies who rely on telecoms for their business practices, or a combination of additional stakeholders.

 

3. The effectiveness of Government policy, legislation, and implementation frameworks for managing national security risks arising from climate change, including those emerging within the private sector.

 

3.1 The CCC states that “Industry links with the Department of Digital, Culture, Media and Sport are effective and managed through the industry-run Electronic Communications Resilience and Response Group (EC-RRG) which represents all major operators. The EC-RRG has committed to regular updates of its report which considers the impacts of climate change on the telecoms sector as well as to voluntary reporting on climate change adaptation. EC-RRG and DCMS work closely with the regulator Ofcom on issues relating to adaptation planning”.[6]             

 

3.2 techUK feels that government policy could focus on enhancing the understanding of the difference between climate adaptation and resilience in the telecoms sector and could seek increased reporting on the latter from industry to help manage national security risks from climate change in the UK. Our view is that there is not a systematic view of the risks to the sector, and this lack should be addressed, and that the telecommunications regulator Ofcom has a clear duty to ensure the resilience of networks (as it will do as enforcement agency for the Telecommunications (Security) Act via forthcoming Code of Practice[7]).

 

4. Allocation of roles and responsibilities at the national, devolved and local level, and the connections between them.

 

4.1 techUK has some concerns about the lack of clarity on regional risk/responsibility dimension of any potential legislation. Although climate risk is likely to affect the whole UK in some form or another, it will be heterogeneous in its impacts. This will overlay existing regional heterogeneity in resilience. Considering this, and the nature of CNI enterprise coverage (telecoms, water, energy), there should be an element of regionality to legislative proposals to avoid exposing certain providers with undue financial burden and ensuring that those at most risk find themselves resourced appropriately. This also asks question of funding; however, this has been addressed elsewhere in this response.

4.2 Telecoms expressed concerns over the competitive disadvantage that companies operating in areas with unique regional risk (coastal, rural, remote) may find themselves at if legislation is not considerate of said risks. This is likely an understated cross-sectoral concern for CNI providers and operators.

 

5. The role of the Government’s forthcoming National Resilience Strategy, particularly in addressing opportunities for (and obstacles to) improved resilience among CNI providers.

 

5.1 There are concerns among the telecom’s community that without appropriate and fair funding models for so called “public good” resilience, above what is commercially viable, it could lead to an uneven burden to upgrade infrastructure on certain providers. This strategy could be important for setting out these fair and equitable funding models that consider the co-dependencies and geographic heterogeneity of risk.

 

5.2 The strategy needs to consider the parallel funding priorities of sectors in scope to avoid undermining one in favour of the other. UK Government’s 5G leadership ambitions are one example where long-term investment is required for success, and which could be slowed by diversion to additional resilience costs.

 

5.3 There are technological barriers to improved resilience in some cases, for example the available battery technology being insufficient for long-term power outages. Innovation in these areas will be key to improving resilience in a commercially viable way.

 

6. The extent and effectiveness of UK-wide monitoring and early warning systems.

 

6.1 Although suitable for most common place weather scenarios, early warning systems and monitoring of climate related risks must modernise with the times. techUK advocates for a dialogue about the use of AI, machine learning, IoT and cybersecurity tech to ensure that EWS are robust, adaptable, and appropriate for known and unknown climate risks, as well as external risks to the infrastructure themselves.

 

7. The opportunities presented by technological solutions (such as AI and digital twins) for anticipating and managing the implications of climate change for CNI.

 

Overview:

 

7.1 As noted in our answer to Question 2 and above, technological solutions utilised in advanced networks, such as Machine Learning and virtualisation, can help to manage the impact of climate change in this CNI sector. techUK sees the role of Digital Twins as a key opportunity. An example is the Climate Resilience Demonstrator (CReDo), a joint effort between Anglian Water, BT, and UK Power Networks to develop, for the first time in the UK, a digital twin across energy, water, and telecoms networks to provide a practical example of how connected data can improve climate adaptation and resilience.[8]

 

7.2 Smart-water metering is one important aspect of the digital efficiency improvements which CNI will need to undergo to improve resilience to climate change impacts. Overview and benefits:

 

7.3 There is significant potential for AI and Machine Learning technology to improve early warning systems. “Nowcasting AI technology” uses real time data insights from satellites to provide early indication of weather impacts on data centres and/or other CNI. The same and similar technologies can be used to identify conditions for failure and recommend remedial actions in response.

Conclusion

 

techUK believes in an open, competitive landscape for companies operating in the critical national infrastructure space. The introduction of new regulation to improve the resilience of CNI should therefore, in our view, be fair and proportionate on all players in the space. Consideration of regional heterogeneity of risk, cost and existing resilience should be central to plans for upgrading CNI. New technologies such as smart water metering, high-capacity battery storage and AI should be employed to make the whole system resilient and adaptable. The interdependencies between different forms of CNI make it preferable to take a whole system view when aiming to improve resilience.

 

25 February 2022

 

 


[1] Climate Change Committee, 2021 Progress Report to Parliament (link)

[2] UK Climate Risk Independent Assessment (CCRA3) - Technical Report Chapter 4: Infrastructure (link)

[3] BBC News - Storm Arwen: Why power cuts left people unable to phone for help (link)

[4] The UK Telecoms Supply Chain Review (link)

[5] 5G Supply Chain Diversification Strategy (link)

[6] CCC: 2021 Progress Report to Parliament (link)

[7] New powers for Ofcom to oversee security of telecoms networks (link)

[8] CReDO Digital Twin (link)