First, check the main guidance on how to develop a management system under an environmental permit. This guidance explains how to integrate climate change adaptation into your management system. You will need to consider
The detail in your risk assessment and plan of action should reflect the risk that climate change creates for your operation. Why you need to plan for climate change impacts
Climate change means that extreme weather incidents are becoming more common and more severe. Climate projections show that over the coming decades we will face an increased risk of climate change impacts, including
All of these could have an impact on businesses directly, in your supply chains and for your consumers and markets. Planning for this will help you to
The ISO 140902019 standard on adaptation planning can also help you consider climate change when you develop a management system. You can complete the process in 6 stages. 1. Preparation
Review what processes you already have in place to
Your preparation work should be based on how complex your operation is.
2. Find potential impacts
Site-based impacts
Consider how vulnerable your site is to current and future climates. You should assess for a 4C rise by 2100 and plan for a 2C rise by 2050. Find any site-specific issues. For example
Find out if there are significant receptors people, animals, property and anything else that could be affected by a hazard nearby. Examples are
Consider if their vulnerability to emissions or incidents increases with changing weather patterns. Consider if this creates a risk for your permit compliance. You can get basic climate change impact data from the Environment Agencys climate impacts tool. You can get more detailed analysis of the risks from the Environment Agencys third climate change adaptation report. Consider relevant impacts on any other sites your company owns or operates. Find out if lessons learned from international operations, which may face different or more extreme weather, can be transferred to your site. Consider how long are you planning for your site to be operational. The severity of climate change impacts could increase with time. With warmer summer air temperatures at a site, you may see an operational impact of needing more water. This may lead to an environmental impact of increased water abstraction, above your abstraction licence or permit limit. You may find a risk to operations from reduced summer rainfall which leads to lower river flows. This may not affect your operation directly, but the reduced capacity for the water environment to deal with any discharge may lead to environmental harm at a significant receptor. Or there may be a lack of water for dust suppression. Very high summer temperatures may happen more often.
The impacts of this are varied but could include
You may experience intense rainfall, especially during the winter months. The impacts are varied but can include
Sector-based impacts
Find climate hazards relevant to your sector or business activity. Consider how these climate hazards could affect your activities known as a risk pathway during normal and abnormal operations. Note any environmental impacts that could result. The industry sector examples for your risk assessment give predicted climate impacts for 2050 based on UK climate projections UKCP18. There are different examples for each sector but the impacts are often common and give common issues and potential mitigations as a starting point.
3. Complete your risk assessment
You may have already completed a risk assessment if you recently applied for a new bespoke environmental permit. If not, you will need to check if you need to manage each risk before you produce an adaptation plan. Complete a standard risk assessment
Complete your risk assessment based on
If your operation is at high risk complete a more in-depth risk assessment
After you complete the standard risk assessment it may be clear that your operation is at a higher risk from climate change. If so, you should
The Met Office has published guidance on how to use the UKCP18 land projections to help you choose the set of projections that meet your needs. You may need specialist advice to quantify some climate risks. To develop a more detailed assessment you can follow
Consider the timing of risks and when they will become significant. Its important to consider thresholds for action. Some risks may be immediate, needing urgent action. Others may be more gradual where you could act later. Some future risks may need action now to make sure they are managed in the future. For example, if your risk assessment shows that you will need a different process in 5 years to cope with higher ambient temperatures, and it will take you 4 years to commission the new plant, then you should start work on this now. This is known as creating adaptive pathways. These allow you to carry out measures in phases based on the timing of the risks. Summarise your evaluation of each risk in a table or suitable template. Review your risk assessments periodically to make sure they reflect current scientific knowledge on climate impacts and your activities. You should record the risk assessment review requirements in your management system. Nuclear sector
If you operate in the nuclear industry or a site for radioactive waste disposal, check the Office for Nuclear Regulations position statement on how the nuclear industry should use UKCP18. Control of Major Accident Hazards COMAH
If you are in scope of the COMAH regulations, then you need to understand if climate change impacts could change the risk of a major accident. You may need to assess climate change impacts in more depth when
Guidance on best practice for climate change adaptation is continually improving. For the latest advice you should discuss climate change impacts on your operation with your COMAH competent authority team. 4. Find control measures
You then need to find control or management measures for the significant risks you identified. These measures could
Gather information on options available to address the risks. Assess if they are reasonably practical and affordable to ensure compliance with your environmental permit. You will need to justify your decisions. For example, adapting your current site to address the threat of flooding may be more expensive than moving your operations to another site with a lower flood risk. Consider the industry sector examples for your risk assessment. Evaluate potential options, considering factors such as
It may be useful to consider an adaptive pathways approach where measures are introduced in a phased manner over several years or longer as the climate changes and the impacts are better understood. This could fit in with the monitoring and review cycle in your plan. For an example of an adaptive pathways approach, check the Environment Agencys Thames Estuary 2100 strategy.
This was designed to be adaptable to different rates of sea level rise. Document how you found and assessed options to mitigate and manage the effects of climate change on your operations. Keep records of the risk assessment and consideration of control measures. This will help you prove to the Environment Agency that you have taken all measures necessary to control natural hazards influenced by climate change. 5. Write your adaptation plan
Aim to write your climate change adaptation plan in line with a suitable standard, such as ISO 140902019. This should make it easier for you to embed it into
From the start, consider a wide range of options for each problem. This is so you do not reject and miss potentially workable options later. You should try to find options with minimal or no secondary implications. These are known as low regret or no regret options. You should try to find options that
Its essential you avoid the problem of lock in of not being able to change your approach when you need to.
You should plan for
Again, using an adaptive pathways approach may help. Like in the Environment Agencys Thames Estuary 2100 strategy. The outcomes of the assessment and adaptation plan should form part of your site management systems where appropriate. 6. Monitor, record and review your plan
You should then monitor your climate action plan to check if
To help your monitoring, you should record severe weather events and near misses and the effect they have on your business. You should monitor impacts on your supply chain where this threatens environmental compliance. For example, where your abatement technology for emissions to air relies on a particular chemical product. Lost production time or environmental incidents caused by severe weather events could influence future decision making on the site. You should also learn lessons from any global severe weather events where impacts on industry have been similar to the risks associated with your business. This monitoring is a vital element of climate change adaptation planning. You should record what youve learned from near misses or events to inform the future planning process. You could log these in a table, recording the
You need to decide who will be responsible for reviewing the plan and how often they need will do this. These reviews could coincide with scheduled reviews of other business systems. The Environment Agency recommends you review your plan every year, or sooner if a factor that has influenced your strategy changes significantly. For example, this could be when
If your permit has a climate change condition, you must review and, if appropriate, update your climate change risk assessment at least every 4 years. During a review, consider
How the Environment Agency checks compliance
The Environment Agency will inspect or audit your climate change risk assessment and adaptation plan periodically. This will be as part of wider checks on your management systems during routine compliance assessment activities. They will plan this regulatory work based on the significance of extreme weather threats, so that its proportionate to
They will also audit the adaptation plan after any significant pollution event that they believe was related to severe weather.