Written evidence submitted by Rt Hon Michael Ellis QC MP, HM Paymaster General
I am writing to you in my capacity as Minister responsible for resilience and security to provide written evidence for the Joint Committee on the National Security Strategy's Critical National Infrastructure and Climate Adaptation inquiry. I am charged to ensure that the security and resilience of Critical National Infrastructure is a top priority for the Government.
The Government recognises the chronic risk posed by Climate Change and endeavours to tackle and improve the situation; this is a high priority for the Department of Business, Energy and Industrial Strategy (BEIS) and the Department for Environment, Farming and Rural Affairs (DEFRA).
I have provided an overview of the Government’s work in this area in Annex A.
ANNEX A: WRITTEN EVIDENCE SUBMISSION
Long term resilience to climate change
- While the Government accelerates its effort to end the UK’s contribution to climate change, it must continue to take robust action to ensure the country is well prepared to face the challenges the changing climate is bringing. The Government considers climate change adaptation to be a priority within its long term strategy; for example, the UK was one of the first nations in the world to enshrine climate adaptation into law within the Climate Change Act. This framework provides a robust basis for the Government to keep track of the diverse set of climate risks the UK faces. The systematic consideration of risk ensures that a coordinated response to these challenges can be developed as the Government seeks to further its adaptive progress.
- The Government also engages with national stakeholders on climate resilience by supporting organisations reporting under the Climate Change Act’s Adaptation Reporting Power (ARP). The latest round of reporting concluded in December 2021. The submitted reports, covering upwards of 90 individual bodies, describe what actions are being taken to strengthen preparedness for climate risks. Reporting covers key sectors including water, energy, transport, environment, health and finance.
- The CCC has also published reports that list evidence of climate risks and provides advice to the Government.
Building Resilience in Energy Infrastructure
- The Government is committed to improving and maintaining the resilience of UK energy infrastructure, networks and assets in the face of future system changes and climate risks. For example, BEIS is working with the energy industry, regulators and other stakeholders to reduce vulnerabilities and ensure an effective response to actual or potentially disruptive incidents to ensure security of supply.
- The Government accepts that climate resilience must be reflected in the wider energy system governance, and BEIS and Ofgem are jointly consulting on proposals for an expert, impartial Future System Operator who will champion progress towards Net Zero, maintain energy system resilience and minimise costs for consumers.
- The Government acknowledges the climate risks of an increasingly renewable-based electricity system, particularly from offshore wind. Alongside working with Ofgem and National Grid Electricity System Operator to manage these risks, BEIS is also currently considering how to ensure flexible demand and supply are taken into account, as well as working to decarbonise flexible firm capacity to ensure when renewable output is lower, and that the Government has secure capacity which meets our net zero ambition.
Assessment of Climate Change Risk
- The Government assesses climate change risk through two complementary processes: the National Security Risk Assessment (NSRA) and the Climate Change Risk Assessment (CCRA). The NSRA includes a series of risks that are impacted by climate change, including natural hazards such as fluvial and coastal flooding and international trends. The CCRA is a five-yearly assessment of the risks of climate change in the UK which endorses the findings of an independent and expert technical assessment carried out by the Climate Change Committee (CCC).
- The NSRA assesses the likelihood and impact of the most serious malicious and non-malicious, chronic and acute risks facing the UK and our interests overseas over the next 2-5 years. A reasonable worst case scenario approach is informed by the expertise of government departments, academia, private sector and the wider scientific community. The NSRA identifies the common consequences of each risk scenario and outlines the types of response and recovery capabilities that might need to be in place to manage the risk. This provides a framework for risk management decision making and contingency response planning at the local and national level.
- Furthermore, the third CCRA, published in January 2022, endorses independent expert advice provided by the CCC in 2021. This risk assessment categorises the urgency of 61 risks across the economy, considering further action in the context of both +2ºC and +4ºC global warming scenarios. The Government will use this systematic risk assessment to build a third national adaptation programme for England, due for publication in 2023, which will set out how the challenge highlighted by the CCC’s advice will be met. The Devolved Administrations are committed to developing equivalent programmes for Northern Ireland, Scotland and Wales.
Key vulnerabilities and levels of preparedness
- In January 2022 the Government published its third CCRA, which endorses the findings of an independent and expert technical assessment carried out by the CCC. The CCRA identified 61 physical risks of climate change to the UK, including 13 risks to infrastructure. Risks are posed by flooding, erosion, subsidence, reduced water availability, and extreme weather including high temperatures, high winds and lightning. These all have the potential to occur concurrently.
Possible compound effects of such events
- The CCC’s findings also highlighted the interconnectedness of key infrastructure services as an important risk, leading to the possibility of cascading failures across systems. Infrastructure operates as a system of systems, where vulnerabilities on one network can cause problems on others, and issues can therefore be far reaching beyond the infrastructure sector. The vulnerability of these interconnected systems is complex and may be significantly underestimated. The Government has been developing a tool to understand these interconnections better and accordingly improve resilience, the CNI Knowledge Base.
Level of preparedness and interdependencies between different aspects of UK CNI
- The Civil Contingencies Secretariat (CCS) has developed a shared methodology to help the Lead Government Departments (LGDs) of the 13 Critical National Infrastructure sectors to identify, assess and understand the interdependencies between sectors. The methodology provides a standardised approach to collect the necessary information from all the sectors to support our understanding and monitoring of interdependencies across the UK's infrastructure. The information and data is collated into the CNI Knowledge Base tool which allows users across Government to view CNI data on a map, or as a network diagram, making interdependencies easy to see.
- Senior cross-government groups focussed on resilience, infrastructure and CNI continue to convene to support the implementation of cross-government policy on the security and resilience of the UK’s critical infrastructure, including strengthening our understanding of interdependencies. These groups and the CNI Knowledge Base tool will enhance our ability to share information and to ensure that the most critical elements of the UK’s national infrastructure remain resilient to a wide range of risks, including risks associated with climate change.
- Furthermore, being guided by the methodology of the NSRA, LGDs for CNI sectors and their respective industries plan for major risks relevant to their sectors. In the last iteration of the Sector Security and Resilience Plans, all sectors identified hazards associated with climate change on which they are focusing resilience efforts. Sectors are also encouraged to plan for concurrent risks occurring, especially where they may be interlinked in terms of causation.
Supply chain vulnerabilities:
- The CCC in its findings has highlighted “Risks to supply of food, goods and vital services due to climate-related collapse of supply chains and distribution networks” as one of eight priority risk areas requiring urgent action in the next few years. The Government is committed to building strong supply chains, resilient to both short-term shocks and long-term challenges.
Recent near miss scenarios:
- Whilst the UK’s CNI is generally well-prepared for extreme weather events associated with climate change, already weakened infrastructure, for example at Toddbrook Reservoir in 2019, has been further impacted by severe weather. In early 2021, Storm Christoph had some impacts, although ultimately not significant, on some storage basins in South Manchester.
The effectiveness of government policy, legislation and implementation frameworks
- Government works to ensure risks to the UK, and specifically CNI, are managed effectively. LGDs engage closely and regularly with both public and private CNI owners and operators in their sectors to understand and respond to any changes in the risk landscape. The Government regularly reviews the effectiveness of its policy and legislation in this regard.
- The legislative framework in the Climate Change Act facilitates engagement with the private sector in this domain. The Adaptation Reporting Power (ARP) in the Act allows the Secretary of State to direct “persons or bodies with functions of a public nature”, including many CNI owners and operators, to report to government on the risks they face from climate change and the actions that they are taking to prepare for these risks. The most recent round of reporting closed in December 2021 and the Government received reports covering over 90 individual bodies, representing water, energy, transport, health, the environment, and finance sectors. The Government will publish these ARP reports in early 2021 in line with the requirements in the Climate Change Act.
Roles and responsibilities
- The UK Government works closely with both the Devolved Administrations and Local Resilience Forums (LRFs) across the UK to ensure effective cross-working on issues of CNI resilience and security.
- The Devolved Administrations hold responsibility for certain CNI sectors under the terms of the devolution settlements, and are involved in workstreams to support said security and resilience. Central LGDs and Devolved Administrations are encouraged to work closely together to ensure best practice sharing and collaboration across sectors.
- LRFs are a key part of the framework established by the Civil Contingencies Act (CCA) 2004 to ensure collaborative delivery of emergency preparedness at the local level. Under the Act, local responders, through the LRF, have a collective responsibility to plan, prepare for and communicate emergencies in a multi-agency environment. LRFs play a pivotal role in ensuring that local areas are resilient to the common consequences of risks including those posed by extreme weather events such as flooding; drought and wildfires. CNI owners and operators are often invited to partake in these forums alongside local responders.
- The Government produces National Adaptation Programmes (NAPs) at 5-yearly intervals, which provide a framework for national-level policy responses to the risks and impacts of climate change, but also include a chapter on the role of local government in adaptation planning. The next NAP is due for publication in 2023 and will cover the period 2023-2028.
- Climate change impacts are fundamentally a local challenge – impacts vary from location to location, and local leaders are able to take advantage of local knowledge to tailor interventions to the specific needs of their communities. Central government also works with the Local Adaptation Advisory Panel (LAAP), which was established in 2010 to facilitate dialogue between central government and a number of councils across England on how to best support local adaptation action. The LAAP advises central government and helps to share best practice across its members.
The National Resilience Strategy
- The Resilience Strategy, a key commitment of the Integrated Review, will outline an ambitious new approach to our national resilience. This new approach means that by 2030, we will have improved our ability to assess and understand the risks we face. We will use our systems, infrastructure and capabilities to better prepare for, respond to and recover from risks in all parts of the UK at a local, regional and national level.
- The Strategy is an opportunity to make that step change, by:
○ Understanding the risks we face, including the impacts they could have, and our exposure to them;
○ Investing in preparation to better prevent, mitigate and recover from risks; and
○ Energising and empowering everyone who can make a contribution to UK resilience.
- The Strategy will outline our approach to working with a wide range of partners, including with the private sector and CNI operators. It is being developed following a successful Call for Evidence and extensive engagement with stakeholders, including those that deliver our CNI. The Resilience Strategy will be published in Spring 2022.
UK-wide monitoring and early warning systems
- LGDs work closely with the sectors they represent and experts to anticipate and plan for encroaching issues and risks. CCS works with all LGDs, including those responsible for risks resulting from the effects of climate change, to understand the risk landscape and consider interdependencies between risks and alert Ministers as appropriate.
- With regards to climate change-related hazards, there are several forecasting services that aim to give advanced warning of between hours to a month on events such as severe weather (including on flooding and heat), wildfires and tsunamis.
The opportunities presented by technological solutions
- The CNI Knowledge Base, launching later in 2022, is a technological tool that will aim to help the Government visualise CNI data and understand the interdependencies between CNI sectors. This technology will transform the Government's ability to identify and model the impacts of cascading risks to CNI, including those caused by climate change, and will enable the Government to take data-driven decisions to improve the UK's resilience.
- Furthermore, The National Situation Centre (SitCen) has been established to bring data and analysis together from across and beyond government to form a timely picture of cross-cutting risks. SitCen is taking a systems based approach to mapping out the current and future risk landscape alongside sourcing relevant data, analysis and expertise which can be drawn upon to monitor and respond to risks. This includes risks that might affect CNI resulting from climate change and any outputs or scenarios from digital twins developed by LGDs or CNI operators.
Engagement with CNI operators with regards to extreme weather and climate change
- Each of the 13 CNI sectors has an LGD responsible for security and resilience policy, including preparedness for hazards such as extreme weather, as follows:
- Cabinet Office - Government Security Group: Government
- Department for Business, Energy and Industrial Strategy (BEIS): Chemicals, Civil Nuclear, Energy, Post (part of the ‘communications’ sector) and Space (UK Space Agency)
- Department for Culture, Media and Sport (DCMS): Broadcast and Telecoms (both part of the ‘communications’ sector)
- Department for Environment, Food and Rural Affairs (Defra): Food and Water
- Department for Health and Social Care (DHSC): Health and Ambulance (part of the ‘Emergency Services’ sector)
- HM Treasury: Finance
- Home Office: Fire and Police (part of the ‘Emergency Services’ sector)
- Ministry of Defence: Defence
- Department for Transport (DfT): Transport
- Each sector has its own fora and methods of engagement with industry to ensure cohesive threat and hazard preparedness. For example, the Food Supply Resilience Planning Group (FSRPG) is the government's food industry sector working group specifically for engagement across all NSRA risks with the potential to have an impact on food as a CNI sector, including any climate change related issues, such as the impact on food supply due to extreme weather. This group is made up of industry trade bodies alongside interested Government departments and includes the Devolved Administrations.
- The Infrastructure Operators Adaptation Forum (IOAF) is a cross-sector working group of infrastructure owners and operators supported by the Environment Agency’s Climate Ready team. Its main focus is the reduction of chronic climate risk rather than response to individual acute weather events. For acute risks, for example coastal flooding, LGDs work with their sectors to promote preparedness for a host of NSRA risks via sector-specific forums.
Conclusions: Climate change and implications of CNI (infrastructure resilience)
- In 2018, the Government asked the National Infrastructure Commission (NIC) to conduct a study on the resilience of the nation’s economic infrastructure covering a subset of CNI sectors - namely the energy, water, digital, road and rail sectors. The results were published in May 2020 in the NIC report ‘Anticipate, React, Recover: Resilient Infrastructure Systems’, in which three recommendations were made:
● government should publish a full set of resilience standards every five years, following advice from regulators, alongside an assessment of any changes needed to deliver them;
● infrastructure operators should carry out regular and proportionate stress tests, overseen by regulators, to ensure their systems and services can meet government’s resilience standards, and take actions to address any vulnerabilities; and
● infrastructure operators should develop and maintain long term resilience strategies, and regulators should ensure their determinations in future price reviews are consistent with meeting resilience standards in the short and long term.
- Government has committed to implementing resilience standards for infrastructure operators and to implement an appropriate testing regime against these recommendations (1 and 2), but declined to comment on the details of these recommendations until after the Resilience Strategy had been completed. Government did not comment on the third recommendation, stating that understanding of the wider context of the National Resilience Strategy was required before further action was considered.
- Alongside the Government committing to developing a new Resilience Strategy, the recommendations outlined in the NIC report are being considered as part of the development of this Strategy. In setting out the Government’s vision to 2030, the Strategy will establish a new approach to improve the UK’s resilience to emergencies and adapt to new and/or evolving risks, including non-malicious risks such as climate change. This will include consideration of the role of the private sector and CNI in building national resilience.
1 February 2022