Defra Publishes NAP3 with New Risk Profiles for Digital Infrastructure

Defra’s Third National Adaptation Programme (NAP3) was published on the 18^th of July 2023. This report sets out the evidence base for action on adaptation for the next 5 years and will build on and develop actions from previous rounds (starting in 2012).

In NAP3, the Government responds risks and opportunities outlined in the Climate Change Risk Assessment 3 (CCRA3) published June 2021. This report also increases the scope from NAP2 to include international risks and how they may impact the UK. Three main themes of the report are “action”, “information” and “coordination”.

The previous programme, NAP2 only references the telecommunications sector, with no mention of data centres. In CCRA3 (2021) digital infrastructure only scores a few mentions, with risks named as high and low temperatures, high winds, and lightning. In telecommunications, subsidence named as a threat to small masts. These mentions are not representative of all the climate threats facing the sector.

Despite the relatively low recognition of digital infrastructure and telecoms in previous adaptation documents, NAP3 provides them their own chapters, with techUK’s Data Centre Council explicitly mentioned as a touchpoint for policymakers. We believe this is reflective of continued engagement with the teams at Defra, the Adaptation Reporting Power, and the digital infrastructure resilience team in DSIT (formerly DCMS).

Data Centres Recognised

For data centres, NAP3 recognises their importance for the UK’s modern economy, including their role in financial payments, supermarket logistics and public services. They present an accurate description of the pressures on a commercial data centre operator and stress the importance of uptime. Defra also mention the clustering around the M25, and the associated concentrating of climate risk to the sector.

The report references plan by DSIT to create a strengthened risk management framework for the sector, a policymaking process that techUK are already feeding into. techUK are also named as the point of contact for the sector for fourth round of the Adaptation Reporting Power in 2024. References to the techUK Data Centre Programme prove the effectiveness of the programme's efforts with Government over the past two years, something we intend to build on.

Changes to the Telecoms Risk Profile

The chapter on telecoms details the history of resilience in the sector, the continued efforts to build resilience in the face of climate hazards, and the commitments to preventing single points of failure. Ofcom's guidance on resilience is referenced by the Defra team, as well as powers to require security assessments to meet standards of security and resilience.

The NAP3 report states that DSIT and Ofcom will continue to monitor the need for further action or intervention in the telecoms sector, including reviewing the regulatory landscape to strengthen the sector’s resilience to climate change.

In terms of future information sharing, this is handled by the Electronic Communications Resilience and Response Group (EC-RRG). This forum serves to prevent and monitor threats and risks to services. Future policy advice and best practice on climate coming out of DSIT and Ofcom will be disseminated via the EC-RRG.

Broader Business Operations

NAP3 contains a section on business operations in a more general sense, away from sectoral resilience measures. Issues such a water scarcity, financial impacts, and supply chain disruption are included in this section. Private businesses are expected to invest in their own resilience for sites and supply chains, but government will be providing support in the form of information and regulation.

The Government reaffirms its commitments to provide a regulatory framework which empowers financial market participants with high quality information on sustainability risks. Implementation of Sustainability Disclosure Requirements for businesses and products will be key to this. They also claim that climate-related disruption will be a consideration of the new strategy on supply chains and imports (this is beyond the DBT Supply Chain Resilience Framework).

The full NAP3 report can be read here.

Lucas Banach

Programme Assistant, Data Centres, Climate, Environment and Sustainability, Market Access, techUK

Lucas Banach is Programme Assistant at techUK, he works on a range of programmes including Data Centres; Climate, Environment & Sustainability; Market Access and Smart Infrastructure and Systems.

Before that Lucas who joined in 2008, held various roles in our organisation, which included his role as Office Executive, Groups and Concept Viability Administrator, and most recently he worked as Programme Executive for Public Sector. He has a postgraduate degree in International Relations from the Andrzej Frycz-Modrzewski Cracow University.

Email:: [email protected]
Phone:: 020 7331 2006
Twitter:: @techUK
Website:: www.techuk.org
LinkedIn:: https://www.linkedin.com/in/lucas-banach-50139650

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Luisa C. Cardani

Head of Data Centres Programme, techUK

Luisa C. Cardani is the Head of the Data Centres Programme at techUK, aiming to provide a collective voice for UK operators and working with government to improve business environment for the data centres sector.

Prior to joining techUK, Luisa worked in the Department for Digital, Culture, Media and Sport as the Head of International Data Protection, where she led on the development of elements of the UK's data protection and privacy policy. In her role, she was also the UK official representative for the EOCD Privacy Guidelines Informal Advisory Group.

She has held a number of position in government, including leading on cross-cutting data provisions in the EU-UK Trade and Cooperation Agreement, and in high priority cross-departmental projects when working in the Department of Business, Energy and Industrial Strategy.

She holds an M.Sc. from University College London's Department of Political Sciences.