Comment & Analysis
Within the Environment Agency (England, UK) adapting to climate change is a top priority – one of three long term goals in our corporate strategy, EA2025, is “A nation resilient to climate change”. This goal is at the heart of the work we are now focusing on. Experience has shown that the businesses we regulate can be vulnerable to extreme weather, such as heatwaves, intense rainfall and storms, and other climate impacts, and we are therefore supporting them to maintain compliance so that they can cope with:
- an increased frequency and severity of extreme weather events, as well as gradual changes to weather patterns causing unforeseen challenges;
- disruption and failure of supply chains locally and globally because of climate change;
- increased risks from mean global temperature rises of 2°C by 2050 and 4°C by 2100.
Within our third adaptation report we committed to all regulatory permissions and activities (within those industry sectors that we regulate) supporting and delivering embedding of climate change adaptation, based on a mean global temperature rise of +4oC by 2100, including a corresponding rise by 2050. We are doing this by refocussing on an existing requirement to consider climate change adaptation within sites’ management systems. Most sites that we regulate are required to have detailed management systems in place to support permit compliance.
In August 2022 we launched our revised approach and committed to supporting businesses to update their management systems over time, prioritising highest hazard activities first, such as those commonly found in the oil & gas and chemicals sectors. By 2026 we expect all permitted activities to have appropriate climate change adaptation planning embedded into their management systems. In the meantime, the Environment Agency expects all relevant sites to have at least completed a risk assessment by April 2024. When we assess management systems (through our routine compliance activity), we will offer advice and guidance initially, but by applying increasing scrutiny of management systems over time, we expect to see all sites fully incorporating climate change adaptation planning by 2026.
We have updated the management system guidance to clarify the position for existing permit holders and when they will need to comply with the revised requirements. From 31 August 2022 the overarching management system guidance was clarified to explain what operators should consider and do to help make themselves and their operations more resilient to climate change. These requirements are aimed at supporting permit compliance and reducing the risk of accidents that impact on the environment. They will also in part help to deliver increased business continuity in a changing climate.
Since August 2022 we have been working on developing a package of support measures to help permitted sites embed the requirement to consider the risks to and from their sites due to climate change more fully. There are already sector specific examples of climate related risks to regulated activities and possible mitigations to support the existing requirement which provide a helpful steer on some of the commonly encountered issues. These were recently updated to ensure that they captured learning from the extreme weather events of 2022 such as those evidenced in the recent Met Office report [1].
We are looking to revise these example risk assessments with input from sectors regularly in future.
With assistance and input from industry bodies we have produced a supporting guidance document to help operators comply with the revised requirement to embed adaptation more fully within management systems. This follows quite closely the methodology outlined within the ISO standard 14090. The standard advocates a step by step approach that aligns well with existing standards and is intended that operators will be able to dovetail the thinking into existing management systems that sites are likely to hold through their use of ISO 14001. The structure covers:
— pre-planning.
— assessing impacts including opportunities.
— adaptation planning.
— implementation.
— monitoring and evaluation.
— reporting and communication.
By working with others and reviewing what support already exists, we have been able to produce an example good practice guidance document. Trade associations and other professional bodies, such as the IMechE, can use this to develop their own best practice documents to support their members.
We are also collaborating with our regulatory partners for the Control of Major Accident Hazards (COMAH) regulations and nuclear site licensing to ensure all high hazard industries we regulate are prepared. Operators need to understand the impact of climate change on the risk of accidents occurring and their consequences. Climate change impacts then need to be embedded into procedures for assessing risks and for planning and carrying out the necessary measures to control the risks.
Through the Chemicals and Downstream Oil Industries Forum (CDOIF), we are drafting guidance and learning material that explores good and best practice associated with the prevention and mitigation of Natural Hazard Triggered Technological Accidents and climate change adaptation. We have also been raising awareness of the standards and guidance. For example, we are surveying all COMAH operators to establish their understanding of standards and guidance that support preparedness for accidents with natural causes.
We have also developed guidance for the nuclear industry on the use of the latest UK climate projections jointly with the Office for Nuclear Regulation, Natural Resources Wales (NRW) and Scottish Environment Protection Agency (SEPA).
Critically, all this work will not deliver real change unless our staff are able to engage properly with those that they regulate and help support them to become more resilient to climate change. With that in mind we have worked in partnership with the SEPA and Climate Sense and have developed four detailed training modules that take our regulatory staff through both the fundamentals of climate change, the principles of good adaptation planning, an outline of the ISO 14090 standard, and our role in helping ensure sites are embedding good adaptation planning into their management systems. The training will be undertaken by new and existing staff charged with regulating sites under the Environmental Permitting Regime and will bolster our capacity and capability in this critical area.
We need to act faster than the climate is changing. We need to move at pace and adapt to climate change. We need to embed climate change adaptation into all that we do to ensure and maintain resilience.
Join us for a webinar with the Spence Seaman and Mike Nicholas of the Environment Agency on the 7 November to hear more on how environmental regulation is helping to better prepare for a rapidly changing climate and future weather extremes. Sign up here.
Image credit: Environment Agency
[1] Record breaking 2022 indicative of future UK climate
Adapting industry to withstand rising temperatures and future heatwaves - Report
1st International Conference and Workshop on Climate Adaptation and Resilience