National Adaptation Programme – step change or stutter?

The third National Adaptation Programme, produced further to Part 4 of the Climate Change Act 2008, was published today. With the first two such programmes being roundly criticised for a lack of strategic direction, has anything changed – is this third time lucky for the UK’s climate adaptation asks Alastair Chisholm?

The Climate Change Act 2008 was genuinely world-leading when it passed into law. Over the years, its mechanisms have provided for scrutiny of government policy and performance by the Climate Change Committee.

Its focus is both decarbonisation – via legally-binding ‘carbon budgets’ – and adaptation – via a climate change risk assessment and a requirement for government to produce a ‘national adaptation programme’ (NAP).

Part 4 of the Climate Change Act characterises this as follows:

“It is the duty of the Secretary of State to lay programmes before Parliament setting out —

(a) the objectives of Her Majesty's Government in the United Kingdom in relation to adaptation to climate change,

(b) the Government's proposals and policies for meeting those objectives, and

(c) the time-scales for introducing those proposals and policies”

This must be done in a way which addresses the risks identified in the periodic Climate Change Risk Assessment (CCRA).

Previous NAPs have failed to set out such objectives, supported by a representative and coordinated suite of proposals, policies and timescales. Rather, they have documented any and all pre-existing policies which might be construed as relevant to managing climate change impacts in a large, sector-by-sector compendium.

The programmes did nothing to set the tone, ambition-level or overall direction for climate adaptation at a national level. Nor did they systematically map-across to the CCRA.

Adaptation has been described as the poor relation to decarbonisation, and the Climate Change Committee’s biennial ‘progress in adapting to climate change’ reports have repeatedly flagged gaping holes in the UK’s social, economic and environmental climate resilience.

The Committee said in March: “The second National Adaptation Programme has not adequately prepared the UK for climate change. Our assessment has found very limited evidence of the implementation of adaptation at the scale needed to fully prepare for climate risks facing the UK”, calling for a “step change” in ambition from NAP 3.

Serious risks

The 2022 CCRA identified a range of high or very high risks under all climate change scenarios. These included risks to soils; natural carbon stores; freshwater ecology; infrastructure, housing and business from both flooding and drought as well as cascading risks; human health from heatwaves, and human health from river, surface water and coastal flooding.

Recent experience particularly in summer 2022 shone a light on heat and drought risks to the UK and how quickly events could progress given extreme weather conditions. The clear lesson being that there is insufficient resilience in our housing stock to high temperatures and in our water supply systems to extreme periods of dry and heat. Agriculture and the natural environment also suffered.

And in the UK while we are used to seeing serious flooding on a semi-frequent basis there have been near-misses in recent years: Coastal storm surges hitting during low tide and intense downpours hitting London and flooding underground spaces like basements in the daytime rather than at night. Those and other events could have played out far worse but for luck.

In an interview the recent interim Chief Executive of the Environment Agency John Curtin warned we have to stop thinking of climate risks through the lens of the present and instead look to other parts of the world experiencing weather patterns we are likely to see more of in the future.

As many parts of the northern hemisphere swelter it’s increasingly clear we cannot continue to escape serious impacts through luck and need to invest in more resilience.

Third time lucky?

So has the third NAP delivered what its two predecessors failed to? Is it a clear statement of intent and ambition, a clear-eyed strategy aligned to the CCRA which sets the objectives required by the Climate Change Act?

To give it credit, it makes a stronger play of the need to leverage major programmes across government to achieve the adaptation and resilience we will need to cope with at least 2^oC global average temperature increase and the associated extremes of weather we’re going to see as a result.

This reflects the growing understanding of the breadth of risk, of cascading risks where one exacerbates another. It recognises the need to build preparedness and take timely action widely but especially in key areas such as infrastructure management, housing and planning, farming and land management.

It cross-references the government’s Resilience Framework, National Planning Policy Framework and Environmental Land Management Schemes. And there is considerable read-across with the Environmental Improvement Plan.

NAP name checks the importance of restoring nature to achieving adaptation and resilience outcomes. And it emphasises the importance of setting appropriate regulation and standards for the private sector. It speaks to building capacity in the bodies which manage many of the impacts of climate change, particularly local authorities.

And it acknowledges the complexity of the risk landscape and the importance of coordination between different policies, programmes and bodies. There are research pledges (albeit small in the grand scheme of things - £15million from 2024 to identify the skills, standards and data needs to increase resilience). This is all good and welcome long-term foundation-laying.

What it isn’t though, is a statement of ambitious action that recognises there have been two wasted prior NAPs, informed by clear and unambiguous objectives for each and every key sector facing significant climate risks.

It perpetuates an ability for government to wriggle and not over-commit. At a time when the window for action both on decarbonisation and adaptation is rapidly shrinking. When the leadership doesn’t seem to recognise the links between a healthy resilient environment and the ability to deliver housing sustainably. And when for all the talk of local authority capacity, only a third have enough staff to manage flash flood risk.

Fundamentally, the latest NAP still fails to address those headline requirements of the Climate Change Act. To set those clear objectives to really address the risks identified.

Whilst the preamble might reflect greater appreciation of climate risk complexity and adaptation thinking and planning is gradually spreading, osmosis-like through wider government policy, the urgency isn’t there and it still feels like a quasi-academic exercise. A more informed and joined-up version of the status quo.

All the while Europe bakes on our doorstep and a friendly jet stream gives the UK yet another lucky escape.

Alastair Chisholm is CIWEM’s Director of Policy