DEFRA consultation on strategy for the forth round of Climate Change Adaption Reporting

Yes. We agree with the objectives and principles suggested for the Fourth Round of adaptation reporting. We think that, for water companies, the climate change adaptation reports are a great opportunity to bring together the different planning and reporting processes required by the regulators. These plans (i.e. Business Planning, Water Resources Management Plans, and
Wastewater and Drainage Management Plans) include evaluation and mitigation of risks as well as indicators to track progress on the delivery of the plans, which includes the service provision for customers. The combination of these parameters is a key part to continue to build on the understanding of the level of preparedness of the water sector to climate change, at local and
regional levels.

We also support the proposal for round four to work to a shorter timescale (compared to previous rounds of reporting) with aim of achieving a better alignment of the components of the UK’s Climate Change Risk Assessment.

We agree with the need to make the upcoming requirements ‘lighter touch’ given the shorter timescale. We also agree with the principles described to reduce the burden on reporting organisations and, that reporting should build on previous rounds to improve the quality of reports.

We accept that adapting to climate change will require investment, especially to ensure that people continue to receive the safe, reliable and affordable water and sewerage services they expect. As a result, affordability is an important consideration when adapting to climate change. We support the creation of a single water affordability scheme, which provides support that is broader and more consistent than what is currently available for customers who need this. Furthermore, in the context of the price review process in England (and Wales), involving customers (including future customers) in decisions about future investment plans will allow companies to understand people’s priorities and preferences about what delivers best value.

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We believe that making these reports accessible can bring many benefits. One way to do this is encouraging reporting organisations to create customer friendly, summary versions alongside the main reports. The more accessible the (summary) reports are, the more impact they can have to help raise awareness about the challenges brought by climate change, the actions taken by reporting organisations and, as a call to action.

Early in 2020 CCW wrote to all water and sewerage companies in England setting out our expectations of what we would like to see, from a customer perspective, in their adaptation reports.

One of our asks was to produce a customer friendly, summary report. We were very pleased to see that a handful of water and sewerage companies in England created such reports.

We think that reporting should be made mandatory in round four to increase the level of participation. Under a voluntary system there are organisations that should be reporting but don’t.

This creates information gaps in the (future) assessment of how well adapted the UK is to the challenges of climate change. This would be key for all organisations that rely on infrastructure and/or provide essential services to customers: it shows how risks are being assessed, considered and mitigated, demonstrates action towards resilience and enables progress to be monitored.

Yes, especially if reporting continues to be voluntary for round four.

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In the specific case of water and wastewater companies we support the case-by case to sectoral reporting. Although water companies face similar challenges linked to climate change, their geographical location can make them more or less vulnerable. Also, the nature of the (individual) business planning lends itself for water and wastewater companies to assess and address the risks individually. Having said that, the recent round of regional Water Resources Management Plans helped to provide information at a regional level of how to increase the resilience of water resources by involving a wide range of stakeholders. A similar approach could be taken for adaptation reports, especially for sectors (such as utilities) that have interdependencies to gather insights on these and how to address them.

It is key that any organisation that has been identified as having interdependencies with those organisations that provide essential services provides a report. Doing so will help to identify and address any issues that could affect the provision of the services people rely on and value the most.

We agree with the CCC’s view that regulators should report on how they drive and monitor adaptation progress in their sector. Regulators are best placed to assess progress towards adaptation and to identify any gaps and additional challenges faced by the organisations they regulate.

In addition to those regulators that have provided adaptation reports for their sectors, regulators of organisations that provide essential services, such as OfCom, OfGem, Office of Rail and Road, the Care Quality Commission should be invited to report.

Water and wastewater companies already report on interdependencies and cascading risks that can jeopardise the provision of safe and reliable water supplies as a result of extreme weather events. This is an area that was identified by the companies in their submissions for the third round of the ARP.

The sectors that have interdependencies with the water sector include energy, telecommunications, and highways. These interdependencies and cascading risks have been evident in extreme events such as the freeze-thaw in 2018 and Storm Arwen in 2021.

Yes. It would help organisations understand better what those risks are, consider and implement mitigation measures to reduce them. It will also help to improve preparedness and response, especially to support people in vulnerable circumstances.

Government can help to encourage cross sector working and collaboration by reviewing the ‘lessons learned’ and actions taken to address these following recent extreme weather events, particularly when these have led to service failure and detriment to people.

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The adaptation reports produced for the third round of reporting by most water and wastewater companies were a welcome change from previous ones. Any future guidance should follow and improve on that used for the third round of reporting, and at the same time (as suggested by the main consultation document) allow some degree of flexibility.

We support the proposal to develop a template that balances the need to cover key areas and reducing the reporting burden. In addition to the points in page 22, we would suggest including measures to track progress (even though this reporting period is likely to be shorter than in the past).

We support the argument that greater standardisation would help to provide better comparability between sectors (and their reports) and support the CCC’s national work. As noted in the document (and mentioned by some water and wastewater companies in their most recent reports), this could also help to improve the assessment of interdependencies between organisations.

Yes, we support this principle. Allowing organisations that reported in the third round to focus in updates to actions will help to reduce the reporting burden at a time when reporting timescales are being reduced. It can also help to increase the number of submissions.

To achieve the desired outcome, it will be essential to provide clear expectations and guidance for reporting organisations at the outset of the process.

Yes, We agree with the areas to prioritise to prioritise for the targeted scope expansion. The choice for the canals and reservoirs is an interesting one – given the use of canals in the future to help to transport water and increase the resilience of water supplies, especially in the South of England.

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Water and wastewater companies should continue to be invited to report on their progress towards climate change adaptation.

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For organisations that provide services such as water and wastewater, energy, telecoms it would be useful to understand how they are communicating with their customers – about the challenges these services face as a result of climate change, and the actions they (organisations) are taking to address these challenges. Also, how are these organisations engaging with their customers, as in many cases, there are practical actions that we can all take to adapt to climate change.