Emma Howard Boyd (London Climate Resilience Review)              FRE0065

Written evidence submitted by Emma Howard Boyd, Chair of the London Climate Resilience Review and former Chair of the Environment Agency.

Environmental Audit Committee

Flood resilience in England

About the London Climate Resilience Review (the Review)

Following increasing severity and frequency of climate impacts, including the flash floods in 2021 and the 40-degree heatwave in 2022, the Mayor of London commissioned an independent review to take stock and make recommendations to guide London’s preparations for more extreme weather. 

The Review gathered evidence from individuals, communities and organisations including hospitals, Transport for London, London Fire Brigade, the Metropolitan Police, Borough Councils, UK Government, NGOs, the financial services sector, sports and cultural institutions.  

We considered national and regional climate risks and set out six areas for urgent action to ensure that lives and livelihoods are not disrupted by increasingly frequent and severe shocks from floods, sea level rise, extreme heat, droughts and wildfires. The Review made 50 recommendations for strategic, delivery, capacity building and investment actions. These were directed to stakeholders across London, including the Mayor of London, UK government, local authorities and the community and voluntary sector.

The Mayor has committed to work with national government to take the recommendations forward, and some have already been adopted. At the time of publication (July 2024), the Mayor of London said: “In my manifesto I committed to work to take forward the recommendations of the Review to make our city more resilient to the impact of climate change… London stands ready to work with the new government, which pledged in its manifesto to improve resilience.”

Since the Review’s publication, London has been selected as one of the regions working with the EU’s Pathways 2 Resilience programme to work on the recommendations, including drafting a strategic regional heat plan; London Councils have provided guidance for dealing with climate impacts to local authorities; the Mayor of London initiated a severe heat exercise, Operation Helios, that involved 80 emergency responders and key institutions; that exercise inspired Resilience First to run an equivalent exercise for businesses including HSBC, Zurich Insurance, and AstraZeneca; the London Health Board is formalising the inclusion of climate adaptation in its plans and activities. In the summer, The Times newspaper said the UK government are considering a Minister for Resilience in the Cabinet Office (a recommendation in the Review) which would help bring a “whole systems approach” to wildfire risk, because gaps in preparedness had been exposed.    

The national context

In late October 2024, Spain experienced a devastating flood that killed over 230 people, displaced thousands, and caused extensive damage.

In July 2021, 243 people died in European floods.  In Germany, warnings were sounded but people didn’t know what to do when they heard them. Following that tragedy, the Environment Agency asked: “could that happen in England?” They found that 61 percent of people in England didn’t realise they are at flood risk.

In the UK, we expect to see warmer and wetter winters; hotter and drier summers; more frequent and intense weather extremes[1], putting communities at risk of devastation and loss of life[2]. Prolonged periods of dry weather followed by intense rainfall can be caused by climate change and are expected to become more common.

The national government’s manifesto said: “For too long, Britain has been held back by governments that, because they lack a relentless focus on long-term ends, are buffeted about by events.”

It also said: “Preparing for the future not only means tackling the climate and nature emergencies, but also adapting to the changes they will bring to our environment... Labour will improve resilience and preparation across central government, local authorities, local communities, and emergency services.”

These commitments are long overdue and hugely welcome. Adaptation is non-negotiable.

With the Mayor of London securing an historic third term and with a Labour national government in power, there has never been a better time to make smarter, more resilient choices in the long-term interest. There are an increasing number of organisations calling for the appointment of a Cabinet Office Minister for Adaptation and Resilience with responsibility for the National Adaptation Programme, as we set out on pages 36 and 37 of the Review. (Recommendation 6).

Strengthening flood resilience

1. To what extent are current flood resilience assets and interventions fit-for-purpose and what are the strengths and weaknesses?

London’s Flooding Risks

Rising sea levels

London’s existing river defences currently protect homes, critical infrastructure, and businesses. The Global Commission on Adaptation said: “London’s Canary Wharf and other developments in East London would have been impossible without flood protection from the Thames Barrier.”[3]

Sea level in the Thames Estuary is now expected to rise by around 1.15 metres by the end of this century.[4] Of the total 330 kilometres of flood defences in the Thames Estuary there are 126 kilometres upstream (west) of the Barrier and just 9 kilometres of these (7%) are sufficiently high to last beyond 2050.

Of these: 17 kilometres need raising by between 40-50cm; 30 kilometres need raising by 30-40cm; 12 kilometres by 20- 30cm; 12 kilometres by 10-20cm and 46 kilometres by up to 10cm. Proactive action to strengthen the Thames’ defences presents an opportunity to invest in London’s riverside. The deadline for upgrading defences downstream of the Barrier is 2040.[5]

The current Barrier is expected to last until 2070. The Environment Agency has said that by 2040, they will have selected an option to replace the current Thames Barrier, but they also say: "we ultimately expect to need a barrier with a second set of gates and locks by 2120, regardless of which option we select by 2040."[6] To prolong the Barrier’s lifespan until a replacement is in place, the Environment Agency will have to stop using the Thames Barrier to protect west London communities from fluvial floods by 2035.

Surface water flooding

Flooding poses a lethal risk to Londoners. In July 2021, London was hit by two extreme rainstorms. Some parts of the city received more than twice the average July rainfall in two hours, causing major disruption and over 2,000 properties flooded with stormwater and sewage. More than 30 tube stations were affected; hospital wards were evacuated. Of all properties at risk of flooding (coastal, fluvial, groundwater and surface water) across England, 60% are at risk of surface water flooding.[7]

In November 2023, the Chief Executive of the Environment Agency told the Public Accounts Committee: “What genuinely keeps me awake at night is surface water flooding. In July, we saw a tragic incident with two deaths in Liverpool. We saw multiple fatalities in the west of Germany last year. We saw 25 fatalities in South Korea last year. As a society, we have to take that much more seriously. It is difficult to forecast these very intense rain cells, and often we do not have the necessary warning systems.”[8]

At a roundtable hosted for the Review by the Better Buildings Partnership a major commercial real estate provider in London said 20% of their occupied commercial properties had to be vacated due to flooding from summer rainfall. Analysis from Zurich UK said flooding from torrential rain threatens 42% of the capital’s 301,000 commercial buildings.[9] The average cost of flooding to a home is £30,000 and £82,000 to a business.[10] In its report on the impact of climate change on sports in the UK, the British Association for Sustainable Sport (BASIS) said: “For football and rugby union, the 25%
overall increase in winter rainfall means experiencing wetter conditions more often.” The Chair of the FA Debbie Hewitt has revealed that “...we have something like 120,000 games a season cancelled because the pitches are not playable.”[11]

•         Are there alternative approaches from across the UK and elsewhere which could help inform improvements and innovation?

We highlight several different approaches to flood/climate resilience throughout the Review which could help inform improvements and innovation. Recommendation 34 is of relevance to surface water flooding.

Recommendation for UK government: As part of the UK government’s review into managing the surface water impacts of increases in impermeable surfaces in public and private spaces, consider introducing stormwater charges for people who pave over gardens and incentives to remove paving.

This Recommendation was widely covered in the media. Comments included “The benefits of de-paving would be felt near instantly. In a world where it’s easy to believe positive actions make little difference, that’s powerful.”[12]

There is also widespread support for the urgent implementation of Recommendation 26. Recommendation for UK government: Enact Schedule 3 to The Flood and Water Management Act to ensure that Sustainable Drainage Systems (SuDS) are considered and used to manage surface water, ensuring resilient drainage systems for new developments in both urban and rural areas.

2. How appropriate is the current balance between 'green' nature-based solutions and 'grey' hard infrastructure resilience assets, and what adjustments, if any, are needed to improve it?

•         What role can natural flood management techniques, such as wetland restoration and tree planting, play in enhancing flood resilience while contributing to broader biodiversity and climate objectives?

Alongside reducing flood risk and providing shade, urban nature-based solutions such as street trees, sustainable drainage systems, green roofs and walls can deliver greater footfall for local businesses; better health due to increased physical activity, reduced air pollution, and reduced anxiety and mood disorders; decreased crime rates; and uplift property values.[13]

We devote a whole section in the Review to London’s blue and green infrastructure (pages 102-107) and list relevant Recommendations 39, 40, 41 and 42 below.

Recommendation 47, which is about introducing a market-based system to enable the delivery of Sustainable Drainage Systems (SuDS), could also help provide a mechanism to help pay the way for some blue and green infrastructure such as rain gardens.

3. What changes to the planning system and building regulations are needed to ensure that buildings and infrastructure are resilient to flooding in the short, medium, and long-term?

Our Chapter 3, “The built environment and infrastructure” focuses on London’s buildings, and manmade structures, features and facilities, and the systems like transport, water and power which keep London moving. It considers the role of all levels of government, infrastructure providers, landowners including the public sector and the planning system in delivering climate adaptation. Climate change is not sufficiently embedded in decision making, increasing risks to people and built environment assets.

The Town and Country Planning Association has said the loss of in-house skills in local government undermines the effectiveness of the planning system.[14] Many local authorities identified a lack of staff resources as a barrier to harnessing the planning process to drive climate adaptation outcomes. A skilled, and functioning planning system would support innovation and delivery. Introducing a statutory requirement and investment to support local authorities would create new roles in adaptation.

Recommendations 21, 22 and 24 below are specifically relevant to this question.

Monitoring flood resilience

4. To what extent are current metrics for monitoring the effectiveness of flood resilience fit for purpose, and what improvements could make them more effective?

The National Audit Office’s report "Government resilience: extreme weather"[15] praised the UK government’s Resilience Framework but says “the framework does not set out a well- defined vision for what a resilient UK looks like, including targets and standards for the desired level of national, local or sectoral resilience. For three of the four extreme weather risks we examined (all except drought), government has not specified what outcome it is looking to achieve, such as target levels of preparedness or resilience, or the amount of risk that it is willing to accept in the pursuit of those outcomes (risk appetite). Without these, government cannot make informed decisions about trade-offs between long- and short-term priorities, investment or funding allocation of priority areas. It also makes it difficult for government or other stakeholders to track progress and evaluate how effectively and efficiently government is using public funds to improve national resilience.”

The Second National Infrastructure Assessment makes practical recommendations for how resilience standards and technical standards should be updated.[16]

This is supported by our Recommendation 25: Recommendation for UK government: In line with the Second National Infrastructure Assessment (Recommendations 28 to 31) by 2025, government should work with relevant sectors and update resilience and technical standards above and beyond the minimum projected rise in global temperatures.

Coordination of flood resilience

5. How effectively and how frequently do flood risk management authorities work together to tackle flooding issues and do they have sufficient resources and skills available to carry out their work?

Despite greater coordination of stakeholders since the floods of 2021, London is not prepared for another major surface water flooding incident and lives and livelihoods are at risk. Please see Review Recommendations 25, 31, 32 and 33 below.

Flooding poses a lethal risk to Londoners. Once again this is a nationwide problem with London-specific considerations. In July 2021, London was hit by two extreme rainstorms; some parts of the city received more than twice the average July rainfall in two hours causing major disruption and over 2,000 properties flooded with stormwater and sewage. The voluntary London Surface Water Strategic Group is good but is not currently moving at the pace needed.

London has 33 Local Lead Flood Authorities compared, for example, to one in Essex, despite Essex having a land area two and a half times larger than London. The GLA is not a Lead Local Flood Authority; it has no legal responsibility for surface water flooding and cannot access funds from the Thames Regional Flood and Coastal Committee. Evidence from the London Environment Directors' Network (LEDNet) said: “London’s 33 local authorities deliver most of London’s public services in local communities on the ground. The layer of governance and local democracy that boroughs provide is therefore key – both to short-term resilience & recovery, and to long-term, strategic climate adaptation planning.

Our Recommendation 33 is set out below:

Recommendation for UK government: Based on the work of the London Surface Water Strategic Group, UK government creates a Strategic Surface Water Authority for London, led by an independent and non-political Chair, to promote, enforce, and allocate funds in-line with a strategic London- wide approach to flooding.

A Strategic Surface Water Authority would help ensure a joined-up approach was locked-in to London’s governance and could direct partnership funding to the most impactful projects across the 33 local authorities.

 Resources, funding and support for flood resilience

8. What level of flood resilience is required to address the flood risks identified in the Climate Change Risk Assessment and is current funding adequate to meet these risks effectively?

The House of Commons Committee of Public Accounts (PAC) report on Government Resilience: Extreme Weather has found that regulation, investment and action on resilience to extreme weather are not sufficient in the face of climate change and increasingly extreme weather, putting the UK at great risk. Their report clearly states that “Government is too focused
on short-term reactive responses at the expense of developing the UK’s medium- and long-term resilient to extreme weather events”. The PAC recommends that “The Cabinet Office, working with HM Treasury and relevant departments, should ensure sufficient focus is given to building the UK’s medium- and long-term resilience to extreme weather events....”. The report sets out that Cabinet Office and Treasury do not know how much money is spent on resilience to extreme weather events, or other national risks, and that some regulators do not have a statutory climate resilience remit, which is holding back UK resilience.[17]

9. How can the Government encourage more long-term private investment in flooding defences and resilience measures?

Our Chapter 4, “A Climate Resilient Economy” looks at how to attract investment and finance for adaptation and climate resilience in London. Investors need confidence that they will benefit directly from the money they put into resilience services over the short and long terms. While there is much that financial institutions can do to understand the investment case for greater adaptation-focused finance, this will not be a substitute for clearly defined policy ambitions and legislation, including standards for homes, buildings and infrastructure, to provide both clarity on what needs to be achieved but also, in some cases, the investment case to grow market opportunity.

The report “Mission Climate Ready” said “Until now, the private sector has lacked a clear steer on the role they are expected to play on adaptation at the sector and local level and the policy certainty necessary to enable them to align their plans and investments.”[18] London cannot wait until the Fourth National Adaptation Programme (NAP4) in 2028 for strategic direction.

Please see Review Recommendations 44, 45, 46, 47,48, 49 and 50 below.

10. What support do property owners and neighbourhoods require to enhance their resilience to flooding?

Please see our Chapter 2 “People and communities” and Recommendation 12.

ANNEX - FULL LIST OF RECOMMENDATIONS

Chapter 1 Enabling London to Lead

1. Recommendation for the Mayor: lead collaborative work with local authorities, the private sector and others to set out
   a clear strategic vision for what it means for London to be adapting well to climate impacts by 2030 and beyond.
2. Recommendation for the Mayor: Work collaboratively to develop an adaptation delivery plan to support London’s strategic vision and lead an exercise to map roles and responsibilities.
3. Recommendation for the Mayor: Build on work already underway to embed climate adaptation as a cross cutting organisational priority across the GLA’s work and funding, where the GLA has discretion.
4. Recommendation for the Mayor:
   The GLA and London boroughs’ finance processes should include a set of questions about climate risks to ensure spending is climate resilient, and the GLA Group’s functional bodies should set adaptation plans and measurable targets.
5. Recommendation for London’s local authorities: Develop climate adaptation action plans, informed by climate risk and vulnerability assessments.
6. Recommendation for UK government: Delivers its commitment to a new process for assessing chronic risks by the end of 2025 and appoint a Cabinet Office Minister for Adaptation and Resilience with responsibility for the National Adaptation Programme.
7. Recommendation for the Mayor: In the context of cascading failures due to increasing climate-related risks, consider how the new London Resilience Unit can further strengthen the GLA’s approach to managing systemic interdependencies and risks.
8. Recommendation for UK government: Introduce a statutory duty for local authorities, other public organisations, and major landowners to adapt to climate change, based on a clear framework of local roles and responsibilities. Funding should be provided in local authority and public sector settlements to meet the duty.
9. Recommendation for the Mayor:
   A regional strategic plan for adapting to higher temperatures in London to be developed with a governance framework that sets out roles and responsibilities.
10. Recommendation to the London Resilience Partnership: Conduct an exercise to test London’s preparedness for a severe heat episode and identify potential cascading and concurrent risks.
11. Recommendation for UK government: Develop funding programmes and increase fiscal devolution for regional and local organisations to accelerate climate adaptation.

Chapter 2 People and Communities

12. Recommendation for the Mayor, local authorities, community groups and London anchor institutions: Increase action to engage Londoners on climate risks and build their capacity to adapt. Initiatives should be informed by behavioural science, insights based and targeted to ensure that interventions result in behaviour change.
13. Recommendation for UK government, the Mayor, local authorities, equalities groups, funders and the voluntary and community sector: Long term and consistent investment must be made available for sustained community engagement and capacity building on adaptation across London’s community and voluntary sector.
14. Recommendation to the Mayor,
    local authorities, the voluntary and community sector, and faith and belief partners: Continue to grow London's spaces for resilience initiatives and drive a coherent approach.
15. Recommendation for London’s cultural organisations, like the Exhibition Road Cultural Group, and sector representative bodies, like London Sport, businesses, and grassroots organisations: Convene key partners to share best practice on adaptation within specific sectors and create adaptation plans and actions.
16. Recommendation for NHS England in London: Provide strategic leadership and coordination to systems in London to allow them to develop and implement adaptation plans and risk assessments. Support identification of “once for London” opportunities.
17. Recommendation for Integrated Care Boards: Work with their organisations to collaboratively agree an approach to adaptation risk assessment and planning. Coordinate support required for providers and work with partners to set system level adaptation plans.
18. Recommendation for Providers of NHS services: Ensure they have completed a climate change adaptation risk assessment to support development of an adaptation plan.
19. Recommendation for the Mayor: Work with the London Health Board
    to mainstream adaptation action by ensuring that climate mitigation and adaptation are included in any future London Health and Care Vision or strategy, and by considering adaptation in its meetings in 2024/2025 (and beyond). The Mayor could act as a convenor to improve mutual understanding of what London’s priorities are for managing the health effects of climate change and preparing the health sector
    for acute and chronic impacts.
20. Recommendation for the UK Health Security Agency (UKHSA): Ensure responsibility for regional aspects of climate change are clearly defined.

Chapter 3 The built environment and infrastructure

21. Recommendation for UK government: Invest in local planning to address under-resourcing and skills gaps which hinder delivery of climate resilience through the planning system.
22. Recommendation for the Mayor: Build on the London Plan’s leading adaptive policies and ensure that climate change, both adaptation and mitigation, are given greater weight in planning decisions.
23. Recommendation for UK government: In line with the Environmental Audit Committee’s recommendation,252 expand Part O of the Building Regulations to refurbishments.
24. Recommendation for UK government: The Decent Homes Standard and Future Homes Standard should set out specific measures for climate resilience with explicit requirements for managing excess heat (cooling), ventilation, water efficiency, flood resilience and biodiversity. The updated Decent Homes Standard must be accompanied by investment from UK government to bring existing homes to this standard.
25. Recommendation for UK government: In line with the Second National Infrastructure Assessment (Recommendations 28 to 31) by 2025, government should work with relevant sectors and update resilience and technical standards above and beyond the minimum projected rise in global temperatures.
26. Recommendation for UK government: Enact Schedule 3 to The Flood and Water Management Act to ensure that Sustainable Drainage Systems (SuDS) are considered and used to manage surface water, ensuring resilient drainage systems for new developments in both urban and rural areas.
27. Recommendation for the Mayor, TfL, Mayoral Development Corporations, local authorities, social housing providers, UK government, businesses, National Highways, Business Improvement Districts, landowners and managers: Prioritise action to adapt existing buildings and create climate ready streets and roads.
28. Recommendation to the Mayor: Create an “adaptation accelerator” programme which supports organisations to develop climate action plans, as well as the development and delivery of projects.
29. Recommendation for UK government, the Mayor, and local authorities: Ensure both net zero and adapting to climate change are considered in all building upgrade policies and programmes and national funding is made available to support delivery.
30. Recommendation for the Mayor, GLA Group, local authorities: Public bodies in London should incorporate subsidence risk into their plans and take a risk-based approach.
31. Recommendation for UK government, Ofwat and water companies. Plans must be developed to secure the investment and deliver the action required to meet 1 in 500-year resilience standards to droughts.
32. Recommendation for the Mayor: Continue work on the development of sub-regional integrated water management strategies and convene partners to deliver the East London pilot strategy.
33. Recommendation for UK government: Based on the work of the London Surface Water Strategic Group, UK government creates a Strategic Surface Water Authority for London, led by an independent and non-political Chair, to promote, enforce, and allocate funds in-line with a strategic London- wide approach to flooding.
34. Recommendation for UK government: As part of the UK government’s review into managing the surface water impacts of increases in impermeable surfaces in public and private spaces, consider introducing stormwater charges for people who pave over gardens and incentives to remove paving.
35. Recommendation for UK government: Produce a National Wildfire Strategy and Action Plan by 2025. This should define effective wildfire risk reduction measures, including at the rural/urban interface, and be informed by a real- time and dynamic England Wildfire Risk Map by 2028.
36. Recommendation for the Mayor and TfL: Support the Transport Adaptation Steering Group to connect with transport providers in other cities nationally and internationally to develop best practice adaptation for city transport.
37. Recommendation for UK government: As part of the Defra review of the statutory powers and responsibilities to map, monitor, inspect and maintain all assets across all flood risks and coastal erosion, (including watercourses and riparian landowners’ role and responsibilities), due in March 2024, Defra should reconsider the Thames Estuary 2100 10-Year Review Advisory Group’s recommendations.
38. Recommendation for the GLA, local authorities and London Anchor Institutions: The GLA and those who own land bordering the Thames west and east of the Thames Barrier conduct an audit of land they own on the riverbank. They should understand where defences need to be raised and maintained and develop an action plan by 2025 setting out financing and delivery options for raising defences, creating nature-based solutions and sacrificial zones, before 2040.
39. Recommendation for UK government: Increase investment in blue and green infrastructure (BGI).
40. Recommendation for the Mayor: Build on existing tools to develop a strategic framework for the delivery of BGI across London; use this to inform funding programmes and convene partners to drive a strategic approach to BGI across London.
41. Recommendation for Local Authorities: Support a strategic London-wide approach to BGI in London and prioritise funding for BGI.
42. Recommendation for London’s public and private sector landowners and managers: Invest in London’s BGI, embed BGI delivery in strategies, and engage with the Mayor, and local partners.

Chapter 4 A climate resilient economy

43. Recommendation for UK government: A Stern, or Dasgupta, style review into the economics of adaptation
and climate resilience.
44. Recommendation for the Mayor: Commission work to strengthen the evidence base on the costs and benefits of adaptation and climate resilience.
45. Recommendation for the Mayor:
The Mayor's London Climate Finance Facility takes forward approaches that can mobilise greater levels
of private finance into climate adaptation projects, this could include launching a green bond.
46. Recommendation for the Mayor: Include climate resilience as part of Grow London Local’s offer to small businesses.
47. Recommendation for the Mayor: Works with public and private sector organisations to introduce a market-based system to enable the delivery of Sustainable Drainage Systems (SuDS) with funding through planned Street Works Programme.
48. Recommendation for the Mayor: Ensure the Mayor’s skills agenda addresses climate adaptation. This includes the use of the Mayor’s Adult Education Budget and other skills programmes to ensure adaptation is addressed across all skills provision, including the Mayor’s skills academies. Work with London employers through existing structures, like the London Partnership Board and the Jobs and Skills Business Partnership, to coordinate delivery of training and apprenticeships to provide employment pathways which support London’s climate resilience.
49. Recommendation for UK government: Review taxation for products and incentives for activities that support its climate ambitions and strengthen adaptation and resilience.
50. Recommendation for the Mayor: Launch a Climate Resilience Challenge to promote innovation in the capital and help find solutions to address the impacts faced by Londoners as a result of climate change.

January 2025