Written evidence submitted by Network Rail

  1. Introduction

Network Rail owns, operates and develops Britain’s railway infrastructure including 20,000 miles of track, 30,000 bridges, tunnels and viaducts and the thousands of signals and level crossings. We manage 20 of the UK's largest stations and over 2,500 more are managed by the train operating companies.

More than 4.8 million journeys are made in the UK with people depending on Britain’s railway for their daily commute, to visit friends and loved ones and to get them home safe every day. Our role is to deliver a safe and reliable railway. We manage and deliver thousands of projects every year to grow, expand and improve the resilience of the railway network to meet the needs of our passengers and freight users. Weather and climate change impacts are some of our most serious risks and to the people and businesses who rely on us. They materially influence our ability to safely and efficiently operate our services, buildings and infrastructure.

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

The railway is exposed to a wide range of highly variable weather with impacts varying depending on the: location, landscape, asset type and condition and the time, nature and severity of the event. Not all impacts are due to severe events, they also result from the cumulative effect of repeated weather, for example groundwater flooding from days, weeks or even months of persistent rainfall.

Analysis of our impacts over the last 15 years shows that wind and flooding have the largest impact, with adhesion and snow also being significant. However, annual impacts are highly variable with 2018/19 and 2019/20 showing much larger temperature impacts than previously experienced.

The impact of climate change is already felt across our network as it causes more frequent and severe weather events which accelerate asset deterioration and increase the likelihood of critical coping thresholds being exceeded e.g. drainage capacity or critical rail temperatures.

Our Third Adaptation Report (December 2021) details the wide range of work we are doing to improve our understanding of our weather and climate risks and to embed their consideration into our operations from policy development, risk analysis and research through to investments in resilience. Section 7 of the report summarises our most important weather and climate risks, those with a current risk rating of ‘moderate’ and/or a future risk rating for the 2050s of ‘major’ or ‘severe’. Although the risk assessment is based on asset classes rather than specific assets the conclusions can be applied to risk assessment and management for individual assets.

The key risks identified are from:

Further detail can be seen in Section 7 of the Adaptation Report and full detail can be seen in Appendix A of the report - our Integrated Weather and Climate change Risk Assessment).

As the influence of climate change continues to be felt in the average and extreme weather events and their patterns, we expect those associated with higher temperatures, increased and decreased rainfall and sea level rise to increase. Low temperature and snow and ice impacts will decrease but current extremes will still be possible at a lower likelihood. Wind and lighting projections are still of lower confidence, but it is assumed that there will be an increase due to the increasing severity and frequency of storms.

  1. Possible compound effects of extreme weather and other effects of climate change & interdependencies between different aspects of UK CNI

While it is possible for these weather risks to be experienced in isolation they commonly occur together (wind, rain and lightning in a storm), in parallel (heavy rain or snow falls across different parts of the country) and/or in sequence (persistent low intensity rainfall or heavy rain after a period of drought). Under these circumstances we may have to deal with:

      Multiple impacts in one location (e.g. flooding, power loss, tree fall and landslip),

      Multiple impacts across our network which may be adjacent or geographically separated, but which interact,

      Widespread and/or protracted impacts with both local and network impacts (e.g. chronic flooding or drought), and

      The effects of the impacts on other organisations on who we rely (e.g. power supplies, road transport links).

We are constantly working to improve our understanding of compound effects and interdependencies. A recent piece of work highlighted in our Third Adaptation Report has been on developing our weather interdependencies knowledge. We have:

      Identified the key organisations that rely on us, who we rely on, and with whom there is a ‘co-dependency’, and

      Those activities that could be disrupted by weather impacts.

Our findings to date are summarised in the diagram on the next page.


Network Rail’s climate interdependencies - risks and opportunities, Network Rail Third Adaptation Report December 2021


Increasing our knowledge and management of these risks will require significant further work by both us, the organisations identified and those with an overarching CNI risk management role. Whilst much of the devil will be in the detail when managing specific risks, there is a limit to what individual organisations or sectors can do to manage more strategic risks. For example, the recent failure of one of our drainage systems nearly caused the National Blood Bank to flood. Management of the culvert was within our power, but there is the more strategic issue of the centralisation of such an important facility versus a more diverse and potentially resilient model.

  1. 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

Definition of an acceptable level of resilience is closely linked to passenger and regulator views on an acceptable level of service. As risks and impacts increase in the future, so will the delays and disruptions on the railway. We want to keep passengers safe but to do so may result in delaying or cancelling trains which impacts performance. If this reduced performance is not acceptable then more needs to be done to enhance asset resilience. How far we go in designing resilient assets in part depends on how much funding is available as it is not going to be affordable to rebuild all railway embankments. We can’t make this bomb proof and need to tolerate a certain level of risk.

  1. 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

There should be close and continuing alignment between climate change legislation and implementation frameworks and wider resilience and CNI legislation and implementation frameworks.

Whilst climate mitigation has mandatory targets which have driven the need for clear government and departmental policies climate adaptation does not, consequently this area of policy is less mature. Whilst there is currently a lot of work being carried out in this space many departmental policies and approaches do not currently contain climate change adaptation consideration or guidance. We are currently engaging with our regulators to help develop clear requirements to operationalise these considerations into the management of the railway.

Better coordination is needed across different government Departments and CNI sector Regulators in order to align an ‘all threats and hazards’ approach to CNI risk management information and requirements - the rail industry is subject to the Civil Contingencies Act 2004 (CCA), NIS and the rail-specific National Railways Security Programme (NRSP) which takes a more granular approach to risk management. Improved cross-modal/sector risk assessment should be driven by central government through Lead Government Departments.

The introduction of standards and implementation frameworks to define the level of resilience required for various asset types would increase resilience of CNI. Any standards/frameworks must:

      Take a holistic ‘all threats and all hazards’ approach,

      Take a balanced approach to prescribing both prevention and response capability,

      Promote the principle of ‘improved resilience’ whenever CNI is replaced or upgraded, and

      Promote ‘resilience by design’ in order to build-in resilience to new assets.

The NRSP is a rail industry example of how a standardised set of requirements, and effective inspection and regulation has positively driven improvements in security standards at rail CNI sites.

The introduction of any new standards and implementation frameworks should also mandate a cross-modal approach to CNI resilience, coordinated locally and driven by the Lead Government Departments working in concert. The impact of external risks e.g. knock-on impacts from an emergency at another location, need to be shared with CNI operators to mitigate against cascade events.

Careful consideration should be given to encouraging CNI operators, their funders and their regulators, to determine resilience requirements based on sound risk management practices and not to value current financial saving/efficiency over current and future resilience.

Additionally, the role of UK central government must be to provide independent and competent review of local activities, identifying good practice and calling out poor performance. The basis for such assessment must be based upon consistent and coherent set of resilience performance and risk indicators that would enable proportionate assurance activity both now and in the future.

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

As cited previously in this submission there is a need for greater integration of resilience consideration into the policies and guidance of both national, devolved, and local level government and CNI operators. This needs to take a cross-modal approach, coordinated locally and driven by the Lead Government Departments working in concert. It must also address potential administrative and jurisdictional / cross-boundary challenges for example our national remit and organisation structure does not always operationally align with local jurisdictional decision making.

There is a tendency towards siloed asset and threat/hazard management. At a local level, risk management bodies such as Lead Local Flood Authorities and CNI Operators must be liaising to consider the potential compound or cascading impact that a risk event occurring at an external CNI location/site may have upon their own role, responsibility or operation. Information needs to be better shared with dependant CNI operators to mitigate against cascade events.

For example, at a local level - The local risk assessment process, managed through Local Resilience Forums (LRFs), should be strengthened to help local partners to share best practice in order to bring all LRFs up to a very high standard. Past experience shows that some LRFs take a less inclusive approach to Category 2 responders and refuse to involve them in Risk Assessment Groups or fail to invite them to discuss non-transport specific risks, e.g. severe weather, which reduces the quality of the overall process. An example of the negative impact of this is where wider responding organisations do not understand the wide area impacts to both industry (train delays, passenger welfare and financial costs) and other responders of what appears to be localised disruption to the rail network. We have the expertise and experience in planning for rail related risks and it is therefore essential that LRFs have the opportunity to learn from us rather than rely on others without this knowledge. There is also a need to encourage greater consistency of local risk assessments, e.g. to define and standardise what constitutes High, Medium or Low risks.

Effective coordination across CNI operators and government departments will avoid redundancy and rework and potential deliver economies of scale.

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

We have already stressed in this submission our belief in the importance of a coherent, multi-sectoral approach to CNI resilience. Network Rail has provided a detailed submission on the National Resilience Strategy (NRS) and CCA Review in support of this belief. In the last two CNI reviews Network Rail have noticed the absence of effective cross-sectoral engagement. This has manifested in the fact that, for example, Network Rail have had to make educated guesses as to the relative importance to the UK of different ports and their freight flows rather than being able to discuss the matter directly with the port/maritime sector. This will clearly limit the accuracy of our own CNI assessments.  The NRS provides a real opportunity to enhance and foster a multi-sectoral approach to resilience in general and indeed we feel it is a crucial opportunity to do this across CNI sectors.

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

Network Rail, with Train Operators employ a weather forecast provider to monitor and alert adverse and extreme weather events in line with our weather risk thresholds and work is being undertaken to develop this further in line with the recommendations from the Slingo Weather Advisory Task Force.

This is currently undertaken on a sector-by-sector basis and there is no single system which provides detailed and relevant information to a UK-wide audience on weather forecasting and early warning.

  1. Network Rail mitigation activity

Network Rail, and the wider rail industry, are working to improve our resilience to climate change impacts and more widely to disruptive events with these two areas of effort complementing each other. The focus is on developing a risk-based approach to resilience planning, enabling a focus on those risks and assets that are key to delivering safety and performance improvements for passengers and freight users in a cost-effective manner.

In the area of weather and climate resilience our Third Adaptation Report details the wide range of adaptation work we have undertaken since 2015 and lays out our action plans going forward. This covers; building adaptive capacity through improving our relevant policies and standards, rising awareness and developing strategies; research and analysis; stakeholder engagement and investment actions. Some of the key work undertaken includes:

      Developing our Weather Resilience and Climate Change Adaptation (WRCCA) and Environmental Sustainability Strategies;

      Including climate change refences in our CP6[1] investment period (2019 – 2024) asset management policies;

      Publishing our CP6 business plan which includes resilience actions - detail on the actions can be seen in our Route WRCCA Plans;

      The development of our Asset Management WRCCA Plan and the Integrated ARP3[2] Climate Change Risk Assessment;

      The creation of the Seasonal Challenge Steering Group, the Seasonal Weather Management Strategy, the Industry Weather Resilience Programme and the Weather Risk Task Force to improve weather resilience;

      Provision of climate change guidance to the business and progress on incorporating climate change into asset standards; and

      A preliminary review of our weather resilience interdependencies.

Going forward we intend to build on this foundation by:

      Further improving our strategic Weather and climate change adaptation framework, governance and policy and integrate them with our CP7 (2024 – 2029) planning and the development of the Whole Industry Strategic Plan,

      Develop Adaptation Pathways and Strategies and investment plans for our Regions,

      Implement the Seasonal Weather Management Strategy, the Industry Weather Resilience Programme and the outcomes of the Weather Risk Task Force,

      Significantly improving the embedding of climate change consideration into our asset management processes and delivery such as transitioning our drainage strategy to a holistic water management strategy,

      Increasing our interdependencies understanding building on our stakeholder engagement, and

      Developing a Weather Resilience and Climate Change Adaptation analysis framework.

In relation to wider resilience, we have recently introduced a Resilience Steering Committee (RSC) under an Executive sponsor. The RSC will integrate, coordinate and direct activity across all resilience disciplines, emergency management, business continuity, climate adaptation and protective security.

At an industry level we have the Rail Resilience Project (RRP) which commences its delivery phase in April 2022. This three-year project will deliver on the conclusions and nine recommendations from the cross-industry Rail Resilience Review undertaken in Q1 & 2 2021. It will deliver for the first time a coherent industry doctrine across the full emergency management lifecycle. It will be supported by guidance on implementation, a full competency framework for emergency management professionals and structures to improve governance across the industry and engagement with partners.

Improved partner engagement is vital as our industry recognises how heavily dependent we are on certain other CNI sectors – particularly power and telecommunications. Whilst we can, and are, strengthening our overall resilience capability, disruption to either power or telecoms would have a significant negative effect on our industry’s ability to respond to incidents on the network and/or support other responding agencies in the event of a wide-area major incident.

The evidence here and in section 8 of our Third Adaptation Report show how we will play our part in creating a weather and climate resilient railway and the appropriate management of the risks to CNI. There is however a limit to what one organisation can do. For example, in Carlisle we have put the vulnerable electronic equipment on raised platforms which will keep our most important equipment out of the water when the River Caldew floods, massively reducing repair time. However, it’s not realistically possible for Network Rail to prevent the river from flooding.

31 January 2022

[1] CP6 refers to investment control period.

[2] ARP3 refers to Defra’s Third round of adaptation reporting under the Climate Change Act 2008.