Planning
"Acquiring the necessary planning and regulatory consents has proven to be a major constraint in the timely and efficient delivery of large infrastructure projects."
Buro Happold/CIC
The government has recently taken steps to address the long-standing problems with the UK´s circuitous planning process. In 2008, the Planning Act was passed to provide a more efficient planning system for nationally significant infrastructure projects. The legislation replaces eight consent regimes with one for major projects such as railways, ports, roads, airports, water and waste infrastructure1.
The Act also provides for the establishment of a new independent Infrastructure Planning Commission (IPC) to determine the detailed and technical merits of individual applications. However, as yet, no projects have been through the new system, so it remains to be seen if this new Planning Act will be effective in delivering much needed infrastructure more efficiently.
The government must ensure the Planning Act and the IPC are as effective and straightforward to navigate as possible. If this legislation fails to achieve reform due to political decisions or workability issues, further reform will be urgently needed.
Planning Policy Statement 25: Development and Flood Risk
The onus is on English local planning authorities to apply Planning Policy Statement 25: Development and Flood Risk (PPS25), introduced in 2006 and intended to reduce the risk of flooding to new developments.
The Environment Agency provides some guidance to local authorities on the implementation of PPS25 in England, and the equivalent policies in the devolved administrations. The relevant bodies do this by auditing large planning applications, but only in a very small number of cases. This system means that flood risk management policy often conflicts with, and loses out to, local authority targets for the economic development of their region.
ICE believes there is a lack of appropriate engineering expertise within many local authorities. This leaves development control and planning departments without the skills to fully implement the recommendations of PPS25 or other devolved administration equivalents. This sometimes results in development that is unnecessarily at risk from flooding, and/or insufficiently resilient.
The Natural Hazards Team should work with the Department for Communities and Local Government and the Environment Agency to ensure local authorities and infrastructure operators consider resilience in the implementation of PPS25 (or equivalent). The team should provide national guidance, if necessary, to enable local authorities to develop the right engineering capabilities to put PPS25 or equivalent policies into practice.
"In terms of regulation, there are a number of limitations in the existing structure which potentially undermine long-term infrastructure resilience. The current framework for economic regulation of the water
industry can encourage short-term efficiency savings at the potential cost of ensuring that vital infrastructure is maintained and improved to meet future requirements."
Severn Trent Water
"It is known that there is still a significant amount of critical infrastructure being located in areas at risk of flooding."
Buro Happold/CIC
Inadequate regulatory remit
ICE believes that the current regulatory system does not adequately address the long-term stewardship of infrastructure and in particular the protection of our national assets. While there are currently regulatory bodies for some sectors, such as Ofgem for the energy sector and Ofwat for the water industry, some major areas – such as waste and roads – have no over-arching regulator whatsoever. Among the sectors where regulators do exist there is a lack of joined up working, each is only concerned with their own sector.
The focus of regulators and asset owners is consumer price, service level and the bottom line, rather than increasing resilience and funding reserve capacity. At present the government takes no responsibility for the provision of reserve capacity and leaves its delivery to the market. Therefore regulators have neither the remit nor the ability to incentivise asset owners to build reserve capacity into critical infrastructure assets. The regulatory system does not recognise interdependency or approach the critical infrastructure network as a whole.
As well as reserve capacity, it is also difficult for regulators to ensure full precautions are taken against emergency situations. Specific man-made and environmental threats are not always addressed as a matter of course – only in certain instances and not always successfully. For example, several years ago Ofwat had to seek specific advice and support from CPNI to ensure that it could justify water companies´ investment against terrorist threats, due to the narrow definition of its remit.
The government must therefore expand the remit of the regulators to address asset stewardship as well as consumer interests. The regulators must be able to offer private asset owners some incentives to build reserve capacity into their infrastructure and should also be given the power to ensure that contingency planning which accounts for an interdependent system of infrastructure is carried out by asset owners.
Regulators must ensure critical infrastructure receives adequate funding to ensure necessary protection – an action which is particularly important given the current economic situation. Regulators should work with CPNI and the new Natural Hazards Team to ensure that additional spending on infrastructure protection is appropriate and proportional. Spending should be carried out under the supervision of the new single point of authority for infrastructure resilience. This point of authority would also play a key role in identifying the gaps which exist in the regulatory system and suggesting solutions to resolve them.
"Current electricity market arrangements are based on rewarding energy sales, but there is no incentive to install new generating capacity that would be held solely in reserve."
ICE Energy Panel
Lack of specific delivery bodies for all threats
The government has recently rectified the failure to address the impacts of climate change on critical infrastructure by creating the Natural Hazards Team within the Civil Contingencies Secretariat of the Cabinet Office.
This new initiative is to be welcomed but we must now ensure that the Natural Hazards Team has the same amount of power as the CPNI and is capable of providing much-needed leadership to asset owners and regulators. Previous government efforts, such as the National Risk Register encourage, but do not insist, that individuals and organisations think about their own preparedness2. The Natural Hazards Team should provide a `challenge function´ to asset owners (through regulators where they are available), actively ensuring that their recommendations are carried out and that infrastructure is resilient.
The Natural Hazards Team must also work closely with the Met Office to ensure asset owners make the best use of climate change data. One of the Natural Hazard Team´s first jobs should be to prioritise crossreferencing the Environment Agency´s flood maps with the CPNI list of critical assets as a first step to identifying and protecting critical infrastructure at risk of flooding.
The government has acted in some way to address both climate change and terrorism, but the third main threat to critical infrastructure – system failure – remains largely ignored.
System failure can be caused by a lack of proper day-to-day maintenance, or failure to recognise long-term delivery issues. For example, in the next 10 years, eight nuclear power stations will come to the end of their functioning life. A further 8GW will be lost when six coal fired power stations close under the Large Combustion Plant Directive by 2015 at the latest3. Without new energy generation or significant demand management there will be a shortfall, which will affect not only the energy sector but the entire infrastructure network.
ICE recommends that the overview authority for infrastructure resilience acts to address system failure. With an overview of the infrastructure network and open communication channels with regulators, asset owners, local authorities and agencies this function will be well placed to ensure issues of long-term maintenance and delivery across all sectors are effectively dealt with. The role can also add extra weight to the efforts of the Department of Energy and Climate Change to create new capacity to meet the energy deficit.
"While some sectors, notably water and parts of the power network have well developed resilience policies and procedures to address risks, the development in other areas is not as mature. An opportunity exists to roll out the experience gained in creating resilience in the more traditional sectors to the newer ones, and the current structure of CPNI does, we believe, support this."
Carillion
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19 Infrastructure Planning Commission implementation: Route map. (January 2009) A report by Communities and Local Government.
20 Cabinet Office. National Risk Register. Retrieved on 12 February 2009
21 Bird, J. (August 2007) Energy Security in the UK: An ippr fact file. Institute for Public Policy Research.
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