The new UK government has promised bolder action on climate resilience. But what should this look like?
On 25 October, the High Court dismissed a claim brought against the UK government’s third National Adaptation Programme (NAP3).
The Climate Change Act 2008 legally requires the UK to make changes to respond to climate change. Produced every five years, national adaptation programmes set out the actions the government will take.
But NAP3, which covers the period from 2023 to 2028, drew criticism for its lack of urgency.
In July 2023, Friends of the Earth brought a legal claim against the government. They argued that the plan didn’t go far enough to protect people – especially vulnerable groups – from the climate threat.
A new government has since taken office. And while it welcomed the High Court’s decision, it also committed to strengthening its approach to climate resilience in the coming years.
So, what actions should the new government take? Here are five recommendations:
1. Stay the course with NAP3’s positive measures
Despite criticism, NAP3 did introduce some positive policy measures.
It established a cross-departmental climate resilience board to oversee adaptation issues – a responsibility that formerly lay with the Department for the Environment, Food, and Rural Affairs (Defra).
This was welcome. Responsibility for climate resilience and adaptation needs to extend beyond Defra’s remit and across the whole government. The ICE would like to see the government appoint a new climate resilience board as soon as possible.
NAP3 also proposes changes to the adaptation reporting power (ARP), which asks public bodies and infrastructure providers to disclose how they’re addressing climate change.
It recommends realigning ARP periods with wider government timetables – something the ICE has called for.
This would mean the Climate Change Committee (CCC) has the most up-to-date information when it prepares its five-yearly climate change risk assessments (CCRA).
2. Adopt a systems approach to resilience – and soon
Infrastructure is an interconnected ‘system of systems’. A systems approach to resilience allows infrastructure to more flexibly adapt to future risks.
NAP3 kickstarted work with the CCC to adopt systems thinking for its next CCRA.
This will mean more effective planning and application of resilience measures across infrastructure networks.
However, the next CCRA won’t arrive until January 2027. The government can – and should – adopt a systems approach much faster.
NAP3 does include welcome commitments to understand the links between infrastructure systems and address the risk of cascade failure, which the government should prioritise.
These include:
- New tools, including digital twin technology, that allow infrastructure operators to understand climate risk at the system level. The ICE has previously called for the rollout of digital twins to better identify and stress-test climate risks.
- New guidance to improve sector-level reporting on climate risks, including interdependencies and cascading failures, through the next ARP round.
3. Ramp up the response to extreme weather
In April, the Department for Transport (DfT) proposed a new adaptation strategy to address transport-related risks from climate change.
However, there's little else in NAP3 on adapting infrastructure and buildings to extreme heat.
The year 2022 saw the hottest day on record in England. Large parts of the infrastructure system struggled to cope with extreme temperatures.
Nevertheless, NAP3 largely restates announcements already made elsewhere, including in the Environment Act, Plan for Water, and Resilience Framework.
Nor is there a firm commitment to make climate reporting mandatory for infrastructure owners and operators.
Without this information, it’s difficult for the government and regulators to identify and focus on the infrastructure at greatest risk.
At present, adaptation reporting is voluntary.
The previous government consulted on whether to change this – with responses recommending that mandatory reporting comes into force from 2025.
The ICE encourages the new government to act on this.
Providing certainty now would encourage more organisations to start reporting ahead of time.
4. Provide clearer regulation
Various regulatory bodies supervise infrastructure spending in the UK.
But ‘resilience’ doesn’t have a market value. Without an understanding of how regulators should measure and reward it, it's hard to incentivise resilience in the long term.
NAP3 does little to address this.
The ICE highlighted this issue in a 2023 report on climate adaptation and resilience. The CCC has also focused on how regulatory price controls don't incentivise long-term resilience.
To drive investment in climate resilience, the UK needs minimum resilience standards and a clearer climate resilience remit for regulators.
The ICE has also recommended a UK government-led national review of the economics of adaptation to inform clearer resilience standards.
5. Where’s the urgency?
NAP3 contains many positive actions. But it’s still another missed opportunity in the UK’s response to climate change.
The lack of new plans and investment raised questions that the new government should act urgently to address.
Climate change is no longer an uncertain, far-off threat. Its effects are already being felt everywhere.
The CCC has warned of a “lost decade” in action on adaptation.
If NAP3 falls short, the UK could lose another five years to ineffective adaptation action.
This would be hugely damaging to the country’s infrastructure and the people and businesses that depend on it.
The ICE’s view
The scale of the resilience challenge is enormous.
The UK must adapt much faster to climate change. A ‘business-as-usual’ approach isn’t enough.
It’s always cheaper to prepare than it is to rebuild. By failing to invest now, the new government will be kicking the can down the road for future generations to deal with.
But, by moving quickly and prioritising the right measures, the UK has the chance to develop a world-leading infrastructure system that is fit for the needs of today and the future.
The ICE is continuing to engage with Defra, the Environment Agency, and other policymakers to ensure the public gets the resilient infrastructure it needs.
