ICE submission to the Defra consultation on the fourth round of the Climate Adaptation Reporting Power

This submission discusses the ICE’s views on the principles of the Climate Adaptation Reporting Power (ARP), including:

• ARP reporting should be made mandatory to ensure infrastructure owners and operators can understand the impact of failure at both a quantitative and qualitative level. Currently, adaptation reporting is mainly qualitative, which makes it difficult for the government and regulators to compare the degree of preparedness of different infrastructure owners and operators and focus on the less resilient.
• Mandating quantitative assessment, including financial quantification of expected damages/losses or impacts in a ‘do nothing’ scenario, would focus resilience efforts on the most material risks.
• The need to align the ARP reporting window with the timetable for the UK Climate Change Risk Assessment (CCRA) in this and future rounds. This will help to create a more holistic overview of climate risks and fill in coverage gaps.
• All regulators should report on how they are updating regulatory approaches, in relation to adaptation and resilience. Also, on how they are embedding adaptation into their regulatory frameworks to ensure that resilience efforts are focused on the most material risks.
• Defra, under the remit of the ARP, should have the authority to oversee standards of protection for key infrastructure that would be relevant at a systems level. Also, to address concerns around data-sharing by providing equal access.
• ARP guidance should include more information for organisations on what interdependencies are and how they need to be addressed.
• Local governments must be able to assume accountability for the resilience of the infrastructure within the communities they serve. This would be achieved by providing local governments with a statutory responsibility to consider climate adaptation in the development and growth of their communities and local areas. Local planning authorities should set out clear expectations for the information they need from applicants on climate impacts and ensure that it’s accessible to all.
• The government and Defra can assist local authorities through working together, alongside organisations such as the Environment Agency, to provide guidelines on climate risk management best practice.