Memorandum submitted by the Institute of Environmental
Management and Assessment (IEMA)
SUMMARY
— Adapting to unavoidable climate change
is essential for all parts of the UK economy.— 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 Institute of Environmental Management
and Assessment (IEMA) is a professional body of environment practitioners;
our vision is to promote the goal of sustainable development through
improved environmental practice and performance. Of a membership
that exceeds 14,500, over 52% are employed in business and industry
across all sectors of the economy, 26% are in consultancy, 10%
in the public sector and 12% in education. IEMA members largely
work on a broad range of multi-disciplinary environmental issues,
including climate change mitigation, adaptation and resource efficiency.
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,[55]
together with a series of workshops throughout the UK to engage
more directly with environment professionals and support their
continual professional development.
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[56]
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%[57]).
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, eg 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)[58]
for certain developments, and its implementing regulations in
the UK, require project developers to predict the likely significant
impacts on the environment and propose measures to mitigate adverse
environmental effects. At present, there is no explicit requirement
for an assessment of the impact of a changing environment.
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 UK's climate change vulnerability.
26. In addition, strategic environmental
assessment (SEA)[59]
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 UK is vulnerable to a changing climate
and it is essential that action is taken by all parts of the economy
to consider their risks and take appropriate measures to adapt.
In order for companies successfully to embrace the adaptation
agenda, more needs to be done to raise awareness of the business
case. IEMA believes that environment professionals have a significant
role to play in helping businesses to integrate adaptation activities
into their business management processes and to help to mainstream
adaptation thinking throughout the economy.
20 October 2009
55 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, Institute of Environmental
Management and Assessment, Lincoln, UK. Back
56
IEMA membership survey on adapting to climate change-report due
for publication in November 2009. Back
57
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. Back
58
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. Back
59
European Directive 2001/42/EC "on the assessment of the effects
of certain plans and programmes on the environment". Back
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