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Memorandum submitted by The Institute of Environmental Management and Assessment (IEMA) (ACC26)
Summary · Adapting to
unavoidable climate change is essential for all parts of the · Companies need to see a coherent business case for taking action to adapt to a changing climate. This requires a greater awareness of the business risks and opportunities. · Insufficient effort is going into promoting the business case for adaptation. More needs to be done to align the publicly funded business support system to this agenda to ensure businesses understand the case for instigating adaptation activity. · Environment professionals employed across all sectors of the economy are already integrating adaptation activity into their organisations and have a significant role to play in ensuring businesses minimise risk and maximise opportunities from a changing climate.
Introduction 1. The 2. IEMA welcomes the Committee's inquiry into climate change adaptation. While IEMA strongly believes that there needs to be a focus of activity on reducing greenhouse gas emissions to mitigate the impacts on climate, we also recognise the importance of adapting to unavoidable climate change and the benefits that early action will bring. IEMA is supportive of provisions in the Climate Change Act 2008 on adaptation, including the statutory requirements on public bodies and statutory undertakers to report on their assessment of risks from climate change and the statutory requirement for a national climate change risk assessment. 3. IEMA recognises that for mainstream business, action on climate change adaptation will be self-determined and there are no plans to instigate legal requirements or duties to adapt. As such, action to support adaptation in the business community needs to be focussed on demonstrating the value and benefits of planning for adaptation and instigating early action; otherwise UK business will be poorly prepared and exposed to greater risk than would otherwise be the case, potentially making them less competitive. 4. As part of the environment
profession's contribution to climate change adaptation, IEMA has worked closely
with the UK Climate Impacts Programme to support the development and sharing of
adaptation knowledge and understanding.
This has included the publication of an IEMA practitioner guide on
managing adaptation in organisations[1],
together with a series of workshops throughout the 5. In responding to the Committee's inquiry, we have focussed on action that needs to be taken to help business to adapt to climate change and support that could be provided to ensure that organisations are adapting well. In addition, our response draws on the results of a climate change adaptation survey of environment professionals in IEMA's membership, and the extent to which members' organisations are planning for adaptation and the barriers they face.
Getting the adaptation message out to business 6. With the exception of statutory undertakers, such as water and energy companies, businesses will be responsible for determining their own response to a changing climate. Companies will need to identify and assess their climate change risks, and develop and implement plans as appropriate to mitigate those risks. In terms of reporting, the 2006 Companies Act requires quoted companies to include in their business review a description of the principal risks and uncertainties facing the company including environment matters; this may include risks from a changing climate. 7. IEMA believes that this voluntary approach to adaptation in business is the right one. While emissions from companies have the potential to impact on the health of people and the broader environment and so are subject to legal and other safeguards, with the exception of critical national infrastructure, the impact of a changing environment is largely of relevance to shareholders and employees. Therefore, it is largely in the self-interest of businesses to adapt to climate change. 8. However, for this market-based approach to climate change adaptation in business to be successful, companies first need to recognise the business case and the potential risks and opportunities that arise. IEMA is concerned that too few companies will be aware of the business need to consider climate change adaptation; fewer still will take action to evaluate and manage their risks. Experience in the area of business resource efficiency indicates that, even where there are significant potential cost savings to be made which would directly improve profitability, many companies fail to recognise the potential or take action. The likelihood is that climate change adaptation will suffer from even less engagement, because the direct benefits to a business are likely to be far less certain. 9. IEMA believes that there is a strong business case for companies considering climate change adaptation, both in reducing risks and acting on opportunities. However, far more needs to be done to promote and articulate the case.
Overcoming the barriers 10. IEMA recognises that adapting to climate change is not solely a role for environment professionals and that adaptation needs to be integrated into mainstream business management processes, including corporate risk management and business continuity planning. However, we believe that environment professionals have an important role to play in helping businesses to understand the environmental context within which a business operates and engage others in their organisation to integrate adaptation thinking into their work. 11. A survey by IEMA[2] of environment professionals at the end of September 2009 gives a snapshot of activity on climate change activity. Overall, there is a high level of engagement in planning for adaptation (62%[3]). Of particular note is the sector breakdown of members' organisations planning for adaptation: construction 64%; manufacturing 64%; electricity, gas and water supply (76%); transport, storage and communication (65%) and local government (90%). This level of engagement is significantly beyond what might be expected of organisations in the economy as a whole, but it does highlight the value that environment professionals can add in terms of instigating environmental and organisational change. 12. The survey also characterised the extent to which adaptation planning had identified threats and opportunities in the areas of: · Markets - changing demand for goods and services · Finance - implications for investments, insurance and reputation · Logistics - vulnerability of supply chain, utilities and transport arrangements · Premises - impacts on building design, construction and maintenance and facilities management · People - implications for workforce, customers and changing lifestyles · Process - impacts on production processes and service delivery 13. The most frequently identified risk area was in relation to premises (57%); risks associated with logistics (44%) was the area least likely to have identified. 14. However, IEMA is aware that there are a number of barriers to instigating action to reduce climate change risk, even when companies recognise that adaptation is a potential issue and risks are identified. 15. Although a high proportion of members' organisations were planning for climate change adaptation, a number of significant barriers to instigating adaptation activity were identified. Barriers included lack of resources, lack of engagement and a limited understanding of the nature and extent of the risks and vulnerabilities. The results indicate that the significance of the barriers is partly dependent on the sector of the organisation. For example, lack of resources is a significant barrier for 67% of respondents in local government, compared with only 32% in electricity, gas and water supply. In the transport, storage and communication sector, both lack of resources and a limited understanding of the nature and extent of the risks and vulnerabilities are rated as being of high significance by over 40% of respondents. 50% of those in the construction sector scored limited understanding of the nature and extent of the risks and vulnerabilities as being the most significant barriers. 16. We believe that there is a strong link between the different internal barriers. Support needs to focus on engaging people internally and explaining the nature of risks; without this, resources won't be made available to instigate action, particularly when set against short-term business survival during the recession. The behaviour and culture change that is required to ensure adaptation becomes embedded in organisations will not happen overnight. Environment professionals are well placed to ensure that action is sustained over a long period of time. 17. The implications arising from the survey are also that different sectors will require different types of support in order to overcome barriers to undertaking adaptation activity. While we are aware of some sector specific activity that has been undertaken by the UK Climate Impacts Programme (UKCIP), the development of tools to help overcome barriers to adaptation activity are likely to be required.
Business Support & Skills Development 18. The Government's recent consultation "Adapting to Climate Change: ensuring progress in key sectors. Consultation on the Adaptation Reporting Power in the Climate Change Act 2008" stated that: "Adaptation needs to be built into planning and risk management now to ensure the continued and improved success of businesses, Government policies and social and environmental operations. All organisations should therefore be considering the risks to their operations of climate change, and the actions that they consider necessary in order to adapt to climate change. In this way we can all be assured that the country is making progress in successfully adapting to a changing climate." 19. We are in strong agreement with this statement. However, if business is to play its full part in the climate change adaptation agenda, then all relevant opportunities need to be taken to increase awareness and stimulate action. 20. IEMA's evidence to the Committee's recent inquiry into Green Jobs and Skills highlighted the failure of the Government's business support programme and the skills delivery framework to help to mainstream environmental knowledge and skills across all sectors of the economy. We believe that the same failures will be repeated on mainstreaming the climate change adaptation agenda. 21. The Government's gateway to business support is through Business Link's Information, Diagnostic and Brokerage (IDB) service, with an estimated 500,000 interventions per year. We are concerned that Business Link Advisors will lack knowledge and understanding on climate change adaptation and therefore miss opportunities to provide support to businesses. 22. In addition, although there are many Government programmes providing support for business on different aspects of the environment, e.g. Carbon Trust, Envirowise, National Industrial Symbiosis Programme (NISP) and WRAP, none of these provides support on climate change adaptation. Consideration should be given to integrating climate change adaptation into exiting environment support programmes, particularly through supply chain engagement. In addition, we believe there is considerable merit in exploring provision of a more holistic, single programme of environmental support to business that incorporates climate change adaptation, mitigation and business resource efficiency. 23. IEMA believes that many of the skills that are required to integrate climate change adaptation planning and action into businesses are generic in nature, including project management, communication, risk assessment and finance. Any "skills gap" in relation to climate change adaptation is therefore likely to be around knowledge and understanding. Therefore, the focus of any training and support needs to be on mainstreaming adaptation knowledge and understanding across all sectors of the economy. At present, there is no programme to ensure that climate change adaptation is considered by all of the Sector Skills Councils. IEMA believes that the UK Commission for Employment and Skills should be mandated to ensure that climate change adaptation knowledge and skills are embedded across all parts of the skills delivery framework.
Environmental Assessment 24. The current European directive on environmental
impact assessment (EIA)[4]
for certain developments, and its implementing regulations in the 25. IEMA believes that consideration should be
given to how best to ensure adaptation is built into new developments and
project decision-making. For example, a
duty could be included in the EIA regulations for project proponents to include
an assessment of the impact of climate change in their environmental impact
statements. This is important to ensure
that new developments do not increase the 26. In addition, strategic environmental assessment (SEA)[5] and sustainability appraisal are required for certain plans and programmes. However, at present there is no link between these assessments and the need to evaluate climate change risks. IEMA believes that Government should consider how best to integrate climate change adaptation into the EIA and SEA regimes.
Conclusion 27. The
October 2009
[1] Johnstone K, Brown A & Goldthorpe M (2009) Adapting to Climate Change: a guide to its management in organisations
IEMA Practitioner Series Vol 13 July 2009, [2] IEMA membership survey on adapting to climate change - report due for publication in November 2009. [3] Note should be made that the results of the survey are a reflection of adaptation activity in organisations that employ IEMA members as environment and sustainability professionals. [4] European Directive 85/33/EEC as amended by 97/11/EC on the assessment of the effects of certain public and private projects on the environment [5] European Directive 2001/42/EC 'on the assessment of the effects of certain plans and programmes on the environment'. |