Is CNI climate resilient? New Joint Committee on the National Security Strategy (JCNSS) Report Published.

[note: techUK submitted evidence to this committee in February 2022] 

A cross-house committee, the Joint Committee on the National Security Strategy (JCNSS), has published its report on the climate readiness of the UK’s Critical National Infrastructure in the face of climate change. The report, entitled “Readiness for storms ahead? Critical national infrastructure in an age of climate change” examines the sectoral responses to a call for evidence which closed earlier in the year. Topics include key adaptation challenges, regulating CNI, ministerial oversight and funding for climate adaptation and resilience, among other things.  

This report is published in the context of what is described as “a severe dereliction of duty on the part of the Government” in its handling of climate resilience for CNI. The report describes how investment in adaptation can save money in the long run and that the costs of failure are extremely high.  

The report goes on to list the climate change impacts which are already affecting the UK, citing the increased frequency of severe storms, heatwaves, wildfires, and floods over the past decade, as contributing to enhanced infrastructural asset deterioration. Witnesses to the inquiry called for a reframing of climate change from a predictable, gradual process to a “hugely volatile” and unpredictable one. The July 2022 heatwave is given as an example of an unforeseen climate risk. 

Telecoms Sector Resilience 

Telecoms infrastructure is officially classed as Critical National Infrastructure (CNI) in the UK. techUK gave written evidence to the JCNSS regarding the resilience of communications infrastructure.  

The report identified that telecoms provide an essential role in the interdependency of CNI in connecting staff to headquarters, while being vulnerable to energy loss and the effects of flooding, lightning strikes, and high winds. techUK emphasised further that telecoms companies provide access to essential monitoring information for other forms of CNI (see below).  

The report recognised there was uncertainty amongst CNI operators regarding their financial ability to prepare for climate change. The report directly quoted techUK’s comments that “The [telecoms] sector is concerned that a lack of fair and equitable funding models could result in an uneven burden on certain providers to upgrade infrastructure— for example, based on the different risk factors in different parts of the country.”   

The report’s proposals for funding, including the use of a joint-insurance scheme, are more generalised proposals for funding CNI resilience, but could help ensure third-party support for the public good provided by telecoms in their role as ‘the network of last resort.’ techUK outlined that the National Resilience Strategy could set out a fair funding formula that would protect parallel investment in essential 5G network rollout. The report’s proposal for promoting Local Resilience Forums may help in communicating techUK’s recommendation for a ‘element of regionality’ in future legislation.  

The report’s proposal for a statutory forum to be attended by CNI operators and regulators, reporting yearly to Parliament, considers techUK’s recommendation for a whole system approach on CNI resilience. The report also recommended Ofcom be given resilience duties, in addition to its already ‘clear and strongly enforced’ rules providing uninterrupted access to emergency organisations.   

Whole systems thinking will also allow telecoms to improve the resilience of other CNI. BT, Anglia Water and UK Power Networks have co-operated on the Climate Resilience Demonstrator, a form of ”connected digital twins” welcomed by the report as ‘promising’ and deserving of government aid. Developments in monitoring and AI will further increase CNI resilience, including in forecasting.  

techUK emphasised too the need for clarity between resilience and adaptation. The loss of service for BT customers with Voice over IP (VoIP) services caused by Storm Arwen was cited by the report, but the migration, delivered by all communications providers, is essential for the switch-off of the analogue phone network (the PSTN) to improve energy efficiency and deliver more reliable services.  

The report treated resilience as part of adaptation, e.g., ‘if we do not invest time, efforts and resources in climate adaptation—particularly to enhance the resilience of our critical national infrastructure—then there will be an enormous price to pay in future’ suggesting further clarity is needed. 

Wider Digital Infrastructure 

Though telecoms were the focus of the report from the tech sector’s perspective, it is becoming clear that a holistic approach to resilience is required in the face of unmitigated climate risk. The digital economy is reliant on the resilience of telecoms, data centres and energy infrastructure.  

A high degree of resilience in CNI-regulated sectors is currently undermined by a lack of planning and government support for the digital services that they rely on. As of the publishing of this report, data centres are not listed as CNI, despite the crucial role they play in the economy and in CNI listed sectors. techUK is engaging with DCMS on this to bolster resilience. 

techUK supports the JCNSS assertion that connected digital twins are key to adaptation and mitigation to the climate emergency, but this will require investment in innovation. Without greater investment in IoT and digital twin technology, the country could fail to effectively monitor risks as they emerge in the environment. 

Energy sector resilience is hugely important to the delivery of digital and telecommunications services. To decarbonise and modernise the energy sector will require the investment and take-up of renewable technologies, and smart tech, such as IoT. Technology has a role to play in reducing demand through the deployment of energy saving devices in the home.  

Investment in digital resilience is also essential to Local Authorities, reflected in a Climate Change Committee Survey of Local Resilience Forums, in which 59% of respondents wanted more information on risks to digital and IT infrastructure.  

Final Comments 

techUK welcomes the findings of the JCNSS’s 2022 report, and thanks them for their consideration of the views of the membership. The tech sector recognises the risks posed by unmitigated climate risks and will continue to work with government partners to build resilience where required.  

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