NIC0014

Written evidence submitted by the Environment Agency

Executive Summary

The impacts of the changing climate (overheating, flooding, drought, storms and sea level rise) are already observable and will inevitably increase significantly due to historic emissions. As the Climate Change Committee has evidenced, the country is not prepared for even ‘best case’ impacts let alone the trajectory we are currently on. Infrastructure needs to be resilient to these short-term climate shocks as well as the ‘slow burn’ impacts of progressive incremental climate change.
Infrastructure interdependencies and the potential for cascading climate risks are poorly understood and we need better integration across infrastructure sectors. There needs to be greater clarity of the roles and responsibilities of state and non state players at both the national and local level.
The country needs a holistic and systems-based approach to infrastructure and resilience across all government departments. Adaptation and resilience measures should be embedded into all publicly and privately funded projects in the national infrastructure pipeline.
The UK should adopt an ‘adaptive pathways’ approach to climate adaptation and embrace a broad range of resilience actions, reflecting the fact that infrastructure resilience and environmental resilience are fundamentally connected.
A review by HM Treasury into the economics of adaptation would help improve our understanding of how climate resilience can support sustainable economic growth. This could form the basis of a domestic strategy for climate adaptation and more efficient join up between resilience and net zero, thereby benefitting people, nature and the economy.
Government should consider what policy steps are needed to maximise the use of the UK Green Taxonomy for adaptation to ensure private investment is driving critical national infrastructure (CNI) resilience.
Strengthening national planning policy through revision of the NPPF presents an opportunity to further strengthen climate change adaptation policies, including in relation to CNI.
It is important that national monitoring, forecasting and warning systems receive investment and development to keep pace with the worsening impacts of climate change.

Introduction to the Environment Agency

The Environment Agency (EA) is a delivery body, advisor and regulator on a range of environmental, flood risk and energy infrastructure, and an advisor on climate change resilience and spatial planning. We have a key role in delivering and enabling infrastructure which helps to protect people and the environment, including in flood and coastal erosion resilience, water supply, sewerage, waste and regulated industry. We help the country to be better prepared for climate impacts, where we lead on managing and responding to the wide range of risks associated with too much and too little water. We see first hand the impacts of extreme weather and sea level rise on communities and infrastructure.

The EA builds, operates, maintains and replaces significant national flood and coastal defence infrastructure. We operate and maintain approximately 78,000 flood and coast defences with a value of £26 billion. This includes:

approximately 7,000km of linear river and coast defences such as flood walls, embankments, channels and culverts – that’s twice the length of the UK’s motorway network;
approximately 20,000 structures such as pumping stations, flood gates, weirs and tidal barriers;
CNI such as the Thames Barrier which protects 125 square kilometres of central London from flooding caused by tidal surges.

We have an excellent track record delivering flood and coastal erosion risk management (FCERM) infrastructure. Last year we completed the £2.6 billion 2015-21 FCERM capital investment programme on time and on budget, whilst exceeding our target to better protect 300,000 homes from flooding and coastal erosion. We and our partners completed more than 850 projects to better protect communities and the infrastructure they rely on across the country. In addition to better protecting homes, these new flood risk management schemes are also making nearly 600,000 acres of agricultural land, 500 kilometres of railway and 9,400 kilometres of motorways, roads and local streets along with thousands of business and major pieces of infrastructure more resilient to climate change.

We have addressed issues in the call for evidence as follows.

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

The EA’s recent report to Government on climate adaptation under the Climate Change Act 2008 states that the impacts of climate change are already observable and will inevitably increase significantly due to historic emissions.[1] The report highlights five ‘reality checks’ that present systemic challenges to national resilience, including the resilience of CNI:

i) The EA alone cannot protect everyone from increasing flood and coastal risks. Climate change will accelerate sea level rise and alter rainfall patterns. Traditional flood defences will not be able to prevent all flooding and coastal erosion, and this has prompted a shift towards flood resilience approaches to live with increasing risks more effectively (for example, property resilience measures).

ii) Climate change makes it harder to ensure clean and plentiful water. England’s water environment is already under pressure from increasing water demand, pollution, rising temperatures and physical modification. Climate change will exacerbate this. The National Framework for Water Resources [2] and River Basin Management Plans [3] address these pressures, but bold, transformative and sustained action is required to ensure clean and plentiful water for future generations. This is important for infrastructure that relies on the environment to either provide water (e.g., for cooling) or to dispose of effluent (e.g., wastewater, sewage).

iii) Environmental regulation is not yet ready for a changing climate. Climate change will exacerbate risks from (and to) regulated industries, for example, by reducing water availability and increasing pollution risks from heavy rainfall. Environmental regulations were generally not conceived to accommodate such rapid environmental change, and more flexible approaches will be needed.

iv) Ecosystems cannot adapt as fast as the climate is changing. There is a biodiversity crisis as well as a climate crisis. Freshwater ecosystems are particularly at risk from rising temperatures, water demand, pollution and invasive species. Efforts are underway to enable ecological adaptation, but the pace of climate change could outstrip these without transformative action as set out in the Dasgupta Review.[4] Infrastructure resilience is directly related to environmental resilience.

v) There will be more and worse environmental incidents. Climate change is causing more extreme weather to increase the frequency, severity and complexity of environmental incidents, such as, flooding, water shortages and pollution. The EA is preparing for this, but the burden of emergency response will increasingly divert our staff and resources from other activities.

Major events such as the winter floods of 2015-16 demonstrate the vulnerability of CNI to climate impacts. For example:

 local authorities reported more than £250 million in damages to roads, bridges, public rights of way and drainage systems;[5]

 the Highways Agency tracked more than 850 flood incidents on the strategic road network including lane and slip road closures on the M6 motorway;[6]

 flooding of the main electricity substation for Lancaster led to loss of power to 61,000 properties affecting over 100,000 people, with cascading impacts on telecoms, local electronic banking and sales systems, and transport networks.[7]

Although harder to quantify, there are also significant social and welfare impacts from the disruption to infrastructure caused by flooding, such as where roads remain closed for several weeks. For example, it is estimated that between 4,000 and 7,000 journeys a day were disrupted by the closure of the A591 in Cumbria over a six-month period following a landslip during Storm Desmond in December 2015. The impacts of Storm Desmond on local social care provision were also significant, as evidenced in a case study of impacts in the village of Halton, Lancashire.[8]

The EA’s 2020 National FCERM Strategy for England highlights the importance of infrastructure resilience. It describes the proportions of transport and utilities infrastructure at risk from flooding: up to 11% of road, 77% of rail, 44% of air and 78% of port transport infrastructure is at risk; and up to 21% of electricity, 25% of gas, 43% of waste water and 51% of water supply.[9]

Our 2019 Long-Term Investment Scenarios (LTIS) for flood and coastal risk management highlight the interdependencies between different aspects of CNI. The LTIS show that 41% of transport and utilities infrastructure assets are in areas at risk of flooding, comprising 36% at direct risk of flooding and 5% at risk due to dependencies on electricity. Over 60% of properties in England are served by infrastructure sites and networks located in, or dependent on others located in areas at risk of flooding. For every household directly affected during a large flood, about 16 people suffer knock-on effects from losses of utility services.[10]

Whilst cascading risks remain poorly understood, we do know there is a need for better integration around key dependencies and safety critical elements across infrastructure sectors. For example, water company assets in one area may have a certain level of designed resilience but rely on power from electricity sub stations with a lower resilience standard. In any given place, all infrastructure operators need to work together. Failure of one piece of flooding and coastal change infrastructure compromises them all, and, ultimately, the safety of people living and working behind them.

In addition to being resilient to sudden short-term climate shocks such as extreme flood events, CNI also needs to be prepared for progressive ‘slow burn’ issues driven by incremental climate pressures, such as more frequent and more intense rainfall, drought and temperature extremes which impact on infrastructure performance, rate of deterioration and maintenance costs.

Slow burn issues include, for example:

 changing rainfall patterns progressively and incrementally reduce the resilience of water supply, whilst warmer temperatures will increase demand for water;

 low river flows impact on infrastructure which relies on the environment to supply water (e.g., for cooling) and will affect power generation capacity;

 higher average temperatures mean biodegradable wastes may need to be collected more frequently;

 extremes of temperature may lead to increased risk of pipe fracturing, increasing risks of leakage and pollution, and reduced flow conditions.

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

CNI climate resilience requires the capacity to ‘bounce-back’ from shocks and to ‘bounce-forward’ in anticipation of future environmental conditions. Traditional resilience approaches focus on the ‘bounce-back’ aspect of emergency preparedness and response. However, this is likely to become unsustainable in the face of escalating climate risks without a complementary ‘bounce-forward’ strategy.

The EA’s FCERM Strategy calls on the nation to adopt a broad range of resilience actions.[11] We have an excellent track record delivering flood and coastal defences, but we recognise that in some places the scale and pace of change, as well as technical, social and environmental limitations, mean that we cannot protect everywhere from all climate impacts. Disruption will still happen in a resilient nation. In addition to protection, UK CNI’s resilience to climate change must also therefore include planning for, responding to and recovering from climate impacts.

Our FCERM Strategy also calls for an ‘adaptive pathways’ approach to climate resilience. For example, our Thames Estuary 2100 plan includes a series of pathways for different climate change and socio-economic futures. This enables options for managing the future tidal flood risk to be reviewed regularly and revised in line with how the estuary changes over time.[12] Adaptive pathways help integrate climate adaptation into daily activities and projects as well as longer term strategic investment and development plans and enable decision makers to select the right combination of resilience actions at the right time.

Infrastructure resilience is partly dependent upon environmental resilience. For example, warmer water temperatures are expected to destabilise freshwater ecosystems and promote vigorous weed growth and invasive species such as zebra mussels, both of which can block the cooling intakes of power stations. The challenge is therefore not to protect CNI from the environment but to understand that environmental resilience is integral to CNI resilience, and indeed enables it.

Natural capital, green infrastructure and net environmental gain can increase the resilience of more traditional ‘hard‘ infrastructure to hazards, and reduce the need for infrastructure investment and running costs if it is designed in from the outset. Whilst environmental regulation can promote CNI climate resilience, much regulation predates understanding of climate change and consequent rapid environmental change. Outdated regulation may fail to incentivise adaptation or, worse, result in maladaptation by ‘locking-in’ CNI to an unsustainable future.

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

We welcome the government’s record £5.2 billion capital investment in FCERM for 2021-27. However, this investment needs to be considered in the context of wider national infrastructure delivery as well as the increasing level of risk resulting from climate change.

The Infrastructure and Projects Authority (IPA)’s 2021 Analysis of the National Infrastructure and Construction Pipeline sets out nearly £650 billion of public and private infrastructure investment by 2030.[13] The IPA’s analysis identifies over £200 billion of planned investment for announced projects in the pipeline that will occur by 2024/25, during which period we know there will be approximately £3 billion investment in flood and coastal risk management infrastructure. However, £3 billion worth of investment in flood defences cannot secure the resilience of £200 billion worth of wider infrastructure investment.

For this reason, we need a holistic and systems-based approach to infrastructure resilience, which considers public and private investment across all sectors. With climate shocks worsening the UK should begin to systematically embed adaptation and resilience measures in investments across the whole government estate as well as privately funded projects in the national infrastructure pipeline.

The National Infrastructure Commission’s new climate change objective – ‘to consider how its advice can support climate resilience and the transition to net zero carbon emissions by 2050’ – is a welcome step,[14] but more work is needed to ensure that climate adaptation is part of investment and policy decision making across all government departments.

There is good work underway in individual departments with some cross-government collaboration, for example the Infrastructure Steering Group run out of the Cabinet Office. The EA is already working with the Department of Transport to see how we can help build resilience and adaptation measures into investment in transport infrastructure across the country. We are also exploring how we can work with the Department of Education on a similar approach across the whole school estate. Whilst there is good work underway in individual departments this work is generally ad hoc. It needs to become embedded as the standard for all infrastructure, or we will store up exponentially greater costs over the future decades. There is a further role for government to coordinate or mandate this across departments and infrastructure sectors and to ensure that resilience is more embedded in the country’s investment in and transition to net zero.

We know that UK CNI climate resilience will require continued significant investment but there is a gap in our understanding of the economics of climate adaptation. Our LTIS shows the optimum level of investment for FCERM,[15] but we do not know what the overall optimum level of investment is for UK climate adaptation or how this should be balanced between the public and private sectors. The potential economic impacts of climate change have been estimated for the UK at the national scale and could have a significant cost and impact on GDP, but more work is needed to develop this into an economic strategy for investing in climate adaptation. Whilst the government’s Green Finance Strategy 2.0 and the UK Green Taxonomy will go some way towards setting out investment pathways for different economic sectors as part of the UK’s transition to net zero, there is no equivalent strategic approach to climate adaptation.

The government could address this by HM Treasury undertaking a review to assess the economics of resilience. This economic analysis could consider:

the optimal costs and benefits of investing in resilience both nationally and by economic sectors;
what trajectory that investment should follow; and
what is the appropriate balance between public and private investment in resilience.

This review would improve understanding of how climate resilience can support sustainable economic growth and could form the basis of a strategy for UK climate adaptation by identifying key sectors for adaptation and outlining the policies and incentives for achieving a resilient nation.

This work would be the equivalent of the 2021 Dasgupta Review into the economics of biodiversity, which was commissioned by HM Treasury.[16] As we have shown, infrastructure resilience is partly dependent upon environmental resilience, and we also know that nature-based solutions are integral to mitigating and adapting to climate change. A proper analysis of the economics of resilience would enable a single joined-up strategic approach to net zero, adaptation and nature, which would allow us to deliver maximum benefits for the UK while minimising costs.

The UK Green Taxonomy (part of government’s efforts to improve the environment, accelerate the transition to net zero and create green jobs) provides another opportunity to stimulate private investment in CNI resilience. It could do this by stipulating criteria, including adaptation and resilience measures, which specific economic activities need to meet in order to be considered environmentally sustainable.  Government should consider what policy steps are needed to maximise the use of the UK Green Taxonomy for adaptation to ensure private investment is driving CNI resilience.

CNI investment that results in new development is covered by spatial planning policy. The National Planning Policy Framework (NPPF) and National Policy Statements provide a common policy for climate change adaptation and local planning policies are required to be consistent with these. However, levels of detail and prescription on climate adaptation vary. For example, current planning policy provides greater detail on flood risk adaptation than other environmental risks. Strengthening national planning policy through revision of the NPPF presents an opportunity to further strengthen climate change adaptation policies, including in relation to CNI.

In general, planning policy does not emphasise the need to assess supply chain risks. However, this is a requirement of the UK Green Taxonomy and could also be included in all guidance and policy covering CNI. Assessing climate impacts on supply chains is challenging, relying on all suppliers and clients having a shared level of understanding: supply chain risks may be global in nature, and risks may be systemic. Government action is required to provide guidance, data and support to ensure supply chain risk can be managed.

Allocation of roles and responsibilities at the national, devolved and local level, and the connections between them; and the role of the Government’s forthcoming National Resilience Strategy, particularly in addressing opportunities for (and obstacles to) improved resilience among CNI providers

There needs to be greater clarity of the roles and responsibilities of state and non state players at both the national and local level. Integration, coordination and forward planning are essential to enable both ‘bounce-back’ and ‘bounce forward’ resilience. Communities need to better understand their vulnerabilities, individual responsibilities and what support they can expect from service providers whether public or private.

Partnerships are essential to understanding the individual contributions to resilience and allow an increased effectiveness of the societal response. As an example, water companies have a key role across several risks including flooding, water pollution and drought. More investment in terms of time and money is needed outside of the emergency situations to develop relationships, understanding and prevent incidents and risks at source to CNI. This will improve the effectiveness of response during an emergency.

There could be a role for government to coordinate or mandate the relationships between connected or proximate infrastructure, especially where there are interdependencies and the potential for cascading risks or where one operator may create or increase risks for others (for example, where there could be increasing competition for water supplies). In the USA the National Infrastructure Protection Plan (NIPP) coordinates critical infrastructure and key resource protection efforts across the country and between public and private sectors. The UK does not have a corresponding mechanism to coordinate national CNI climate resilience and local adaptation measures.

The forthcoming National Resilience Strategy (NRS) must have a large role to play. The EA has made the following key recommendations in its response to the NRS call for evidence:

Climate change adaptation should be at the heart of the nation’s resilience;

 As a nation we should explicitly plan to be resilient to Catastrophic Emergencies and use the National Security Risk Assessment Planning Assumptions to shape necessary capabilities, preparation, and response;

 We need to put investment in incident management and resilience activities on a secure long-term footing across Cat 1 and 2 responders, including the EA;

 As a place-based organisation we recognise that a strong local response is important, but the EA also welcomes moves for better coordination at the centre;

 We welcome a review of the Civil Contingencies framework – but any new responsibilities need to come with the necessary resource to deliver these.

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

An important part of the EA’s role is to monitor, forecast, warn, inform, respond, recover and advise the public of flooding from rivers and the sea. We maintain national information on the current and future risks arising from all sources of flooding and coastal erosion.

Working with the Met Office in the joint Flood Forecasting Centre (FFC), we provide the most complete picture of national flood risk, from developing weather through to the actual flood event itself. The Met Office, the EA and the FFC provide a world-class forecasting and warning service with approximately 1.4 million properties signed up to receive free flood warnings. Our current warning service focusses on flooding to properties and encompasses subscription alerts, online river levels and location-based SMS alerts. We also share intelligence with our response partners to enable us to co-ordinate and scale our response accordingly. We provide a national forecasting and alert service to emergency responders. The FFC operates 24 hours a day, 365 days a year, giving emergency responders targeted information to prepare for flooding.

The quality of our flood forecasting gives enhanced lead in times for other response services, allowing them to operate more efficiently and effectively. Our systems and processes have been adopted elsewhere, for example in Australia where we have a memorandum of understanding with the Australian Bureau of Meteorology to share learning.

The EA is the closest organisation that England has to a national alerting agency for environmental hazards. We are designing our monitoring, forecasting, and alerting systems to be able to be used for other emergencies, not just flood. For example, as incidents like wildfires become more common there is an opportunity for other risk to life hazards to be included in the system. We also already provide a monitoring service for water quality and low river flows and a forecasting service for bathing water quality.

Collaboration with our response partners is critical – as the challenges our incident management service responds to get bigger and more frequent, we know that we cannot deliver our service alone. We need one environment incident response for England that talks with a single voice and listens, learns and shares what people tell us.

Climate change will increase the frequency and severity of risks to infrastructure. It is important that national monitoring, forecasting and warning systems receive investment and development to meet this demand.

The EA is currently developing a new National Flood Risk Assessment (NaFRA2) that will provide a single picture of current and future flood risk from rivers, the sea and surface water, using both existing detailed local information and improved national data. The new risk assessment will be available as open data and will provide risk management authorities, infrastructure providers, insurers and members of the public with more accessible and trusted data and information for making good investment decisions. The new assessment will launch by 2024 and will be continuously improved to provide the nation’s flood and coastal risk assessment needs over the next 15 years. NaFRA2 will enable us to share more reliable and richer data (including information such as flood depth and duration of flooding) with external users such as infrastructure operators and regulators.

1 February 2022