Executive summary
The Pensions Regulator (TPR) recognises the need to act on both mitigating climate change by reducing carbon emissions and adapting to the impacts of climate change. This document is a high-level climate adaptation strategy which sets out the main risks to TPR from climate change, and the actions that the organisation will need to take to manage these. It comprises a Climate Change Risk Assessment (CCRA), and a Climate Change Adaptation Plan, and meets TPR's requirements under Commitment F: Climate Adaptation of the Greening Government Commitments (GGCs).
The focus of this strategy is on the activities of TPR as an organisation, rather than a regulator. TPR has a small physical footprint compared to the majority of government agencies, and as a tenant in the Telecom House building in Brighton (occupying 1.5 floors), is limited in the amount of control it has over the management of risks affecting the building. As such, the actions identified in this strategy relate primarily to operational measures that TPR can take to manage material risks, as opposed to interventions involving the physical fabric of the building.
Purpose of this document
TPR commissioned consultants AtkinsRéalis to develop a Climate Change Adaptation Strategy to meet the requirements set out under the GGCs and support the fourth round of Adaptation Reporting Power (ARP). This document is complementary to existing and ongoing work being taken forward by TPR in relation to climate change and environmental sustainability.
The GGCs require UK government departments and their agencies to report on climate adaptation progress and the actions they will take to reduce their impacts on the environment for the period 2021 to 2025. In particular, GGC F: 'Adapting to Climate Change' requires departments to take all reasonably practicable action to adapt to climate change and reduce the impact of climate change on their people, estates, and operations. Organisations are required to produce an organisational Climate Change Adaptation Strategy that covers their estates and operations. The commitment has two components.
- Departments should conduct a CCRA across their estates and operations to better understand risk and to target areas that need greater resilience.
- Departments should develop a Climate Change Adaptation Action Plan (CCAAP), including existing or planned actions in response to the risks identified.
The GGC requirements are likely to become ever more demanding with each iteration.
This Climate Adaptation Strategy will need to be periodically reviewed and updated both to take account of evolving understanding of physical climate risks, including in particular low probability, high impact events, and any changes in TPR as a business, including growing internal capacity to integrate and manage risks.
Risk assessment
The key risks identified for TPR relate to overheating, surface water flooding, and disruption to travel networks, ICT infrastructure and supply chains arising from flood and storm impacts beyond the Telecom House site.
Overheating
The likelihood of heatwaves, heat health alerts and number of days exceeding heat thresholds is projected to increase. With this comes additional risk to staff health, wellbeing and productivity. In addition, air conditioning is more likely to be required to maintain comfortable working temperatures.
Flood risk
TPR is located in an area at risk from surface water flooding, with this risk set to rise in line with projected increases in the size and number of extreme rainfall events. While there is limited risk to TPR from flooding from rivers or the sea, it is possible that the water table can rise, causing flooding of the lower floor of the car park at Telecom House.
Travel disruption
With both National Highways and National Rail planning for increased disruption to road and rail travel due to flooding, storms and heatwaves, it is likely that there will be an increase in the number of days that adverse weather requires employees to work from home. While short-term disruption can be managed, longer-term disruption is also possible if significant damage to transport infrastructure arises.
Adaptation plan
The results of the climate change risk assessment, and review of current risk management processes show that TPR as an organisation is well-adapted to climate change risks based on current knowledge and industry practice. The building design and integration of new air conditioning systems significantly reduce the risks associated with overheating, while the organisation’s familiarity with working from home utilising ICT provides additional resilience to both site and travel-related disruption arising from severe weather events and allows business operations to continue with minimal disruption. There are, however, several areas where action could be taken to strengthen resilience, of which resilience to surface water flooding is the most pressing issue.
Actions in the Climate Change Adaptation Plan are grouped according to three themes, which are:
- Ensuring safe, climate-resilient working
- Enhancing physical resilience
- A culture of climate resilience
They are also categorised according to whether they are immediate priorities to be carried out over the next three years, or longer-term actions.
Climate change risk assessment
Background
The impacts of climate change are already being felt across the world. Average temperatures have increased 1.2°C above pre-industrial temperatures, climate extremes are changing rapidly, and historical records are consistently being broken in relation to temperature, rainfall, aridity and storm severity. The impacts of climate change are undeniable and highlight the need to prepare for emerging risks such as overheating, storms, water scarcity and flooding.
Climate change creates a range of physical impacts to the built environment, the workforce and operations. These include loss, damage and disruption from extreme events such as storms, flooding and heatwaves, impacts to staff health and wellbeing, increased costs associated with maintenance and energy demand for heating, ventilation and air conditioning systems, and impacts on provision of goods and services through disruption to supply chains and ICT infrastructure. Of this latter category, provision of broadband and internet infrastructure is of most importance, together with power supply. Climate change will also bring about transition risks as the UK adapts to a net zero economy which will impact business and strategy planning. The rapidly evolving policy and regulatory environment will require regulators to provide robust support and guidance for their sectors to respond to the changing climate-related risks and opportunities and meet reporting requirements.
This assessment follows best practice as laid out in the Cabinet Office Estates Adaptation Framework and the National Audit Office Climate Change Risk: A good practice guide for Audit and Risk Assurance Committees and is supported by UK climate hazard data.
TPR has a small physical footprint compared to the majority of government agencies. We are a tenant in the Telecom House building in Brighton, occupying 1.5 floors, and as such are limited in the amount of control we have over the management of risks affecting the building. We also have a relatively short tenancy period of 10 years with a break clause after 5-years, and as such moving to different premises remains a possibility. This assessment highlights significant risks to the building and distinguishes in the climate adaptation assessment between those risks over which TPR has control, and those which are the responsibility of the landlord. The focus of this assessment is on the activities of TPR as an organisation, as opposed to TPR as a regulator.
Defining the risk assessment
This risk assessment considers TPR's building, utilities, staff and operations. It excludes green space as TPR does not manage any. It includes a medium-term focus using climate change projections for the 2050s and a longer-term view using projections for the 2080s to enable TPR to manage both its medium- and long-term decision making. The assessment covers risks from high temperatures, cold snaps, heavy rainfall and surface water flooding, flooding from rivers and the sea, water scarcity, windstorms and wildfires, and cascading risks associated with each hazard. Risk is assessed as a combination of likelihood and magnitude and accounts for important thresholds in the system to identify critical points where failure may occur.
The assessment uses publicly available data including the 2018 UK Climate Projections, UK Climate Resilience (UKCR) risk metrics, Environment Agency flood maps and Copernicus data (data from the European Union’s Earth observation programme). Alongside this, the assessment also uses information from TPR's Climate Change Strategy, Accommodation Strategy and Corporate Strategy. Effective stakeholder engagement is essential to provide a range of knowledge and perspectives that can guide the risk assessment and develop understanding of the key risks and impacts facing TPR. The report has been informed by a stakeholder workshop, a site visit and calls with TPR staff.
To account for the uncertainty associated with the evolution of emissions trajectories and climate impacts, two climate scenarios are used in the risk assessment. Representative Concentration Pathways (RCPs) 4.5 and RCP8.5 are used to represent a range of possible future scenarios. RCP4.5 represents a 'medium' emission scenario and indicates global warming of around 2.4°C (1.7°C to 3.2°C) and RCP8.5 represents a 'high' emissions scenario indicating global warming around 4.3°C (3.2°C to 5.4°C) for the 2081 to 2100 period, relative to the pre-industrial period (1850 to 1900). RCP scenarios are used instead of the more recent Shared Socio-Economic Pathways (SSPs) as a range of tailored UK climate products have been developed based on RCPs, and Met Office comparison of model projections using the RCP and SSP scenarios shows good agreement for the UK.
Screening climate risks
Climate risk screening is the process for identifying and prioritising the most important risks for an organisation and its strategic and operational decision making. The GGCs require organisations to report against overheating risks to buildings, flood risk, water shortage risks, risks to natural capital and 'other' risks as identified by the organisation. For the purpose of this assessment, risks and opportunities relating to cold-snaps, wildfires and windstorms have also been considered.
The screening stage uses available information from within the organisation such as building characteristics and occupancy levels, national assessments including the third UK Climate Change Risk Assessment (CCRA3), and relevant guidance such as the National Audit Office's Good Practice Guide for Audit and Risk Assurance Committees.
The results of the screening stage identify:
- the most important risks to be taken forward for detailed assessment
- parts of the estate that are the most vulnerable
The climate screening stage uses an in-house tool developed by Atkins to identify high-level climate change risks relevant to TPR. The tool scores risks using available flood and climate change data at the highest available spatial resolution against baseline and future scenarios of +2°C and +4°C warming. The results are presented using scores between 1 (very low) and 5 (very high) for each scenario, illustrating the changing probability of exposure to each hazard from the baseline period. The tool screens risks from:
- flood risk from rivers and the sea
- surface water flood risk
- water scarcity risk
- overheating (cooling degree days – the annual sum of the number of degrees the daily average temperature is above 22°C)
- cold snaps (heating degree days – the annual sum of the number of degrees the daily average temperature is below 15.5°C)
Climate screening results
The results of the climate screening tool are summarised below, in order of risk severity. The risks are presented per climate hazard and giving consideration to offices and buildings, utilities, staff and operations. The results of the screening tool have been supplemented with site specific information as required. The climate screening has identified high temperatures, extreme precipitation and surface water flooding, water scarcity and drought, and storms and high winds to be the key hazards facing TPR. The risks associated with each hazard identified as medium to high sensitivity are taken forward to be assessed in greater depth as part of the risk assessment. Risks relating to wildfires and storms are screened using publicly available climate change data including the 2018 UK Climate Change Projections (UKCP18) and UK Climate Resilience Programme indicators.
Summary of results of the climate screening tool.
Extreme precipitation and surface water flooding
- high risk that heavy rainfall may overwhelm drainage and sewage systems, with cascading impacts resulting from disruption to critical infrastructure
- high risk of impacts to health and safety, including increased risk from mould and respiratory diseases
- high risk that floodwater could disrupt site access and its operations
- high risk of disruption to supply chains
- medium risk of loss and damage to building contents and building fabric
High temperatures
- high risk of impacts to staff health, wellbeing and productivity, subsequently impacting on operations
- medium risk that high temperatures could affect thermal comfort and cooling demand at TPR offices
- medium risk that electrical equipment may be sensitive to high temperatures, with potential for cascading impacts from disruption to ICT, energy and transport infrastructure
Water scarcity and drought
- medium risk that TPR office could face interrupted public water supplies
- medium risk that public water supplies may be affected by drought and could lead to water use restrictions
- medium risk that higher temperatures can increase the peak demand for water on site
- medium risk that operational activities that require water supplies (for example, building services and maintenance) may be impacted
Storms and high winds
- medium risk of impacts to buildings from moisture, wind and driving rain
- medium risk of impacts to energy, water and ICT supply
- medium risk to health and safety from wind-blown debris
- medium risk of impact to operations arising from disruption to infrastructure services
Cold snaps
- low risk of any alteration to heating demand
- low risk of cascading impacts from disruption to ICT, energy and transport infrastructure
- low risk of any impacts to health and wellbeing and subsequent impact on operations
Flooding from rivers and the sea
- low risk of loss and damage to building contents and building fabric
- low risk of cascading impacts resulting from disruption to infrastructure services
- low risk of Impacts to health and safety
- low risk of floodwater disrupting site access and operations
Wildfire
- low risk of damage and loss to buildings
- low risk of damage and loss to critical infrastructure
Climate change risk assessment
This more detailed quantitative climate change risk assessment brings together the results of scoping and screening stages. This step quantifies risks for a baseline and two future scenarios (RCP4.5 and RCP8.5), which considers the probability of hazards and consequences in economic, social, environmental and reputational terms.
The sections which follow assess the key climate risks for TPR and provide climate risk scores for the priority physical climate risk scores based on the scoring system in Figure 1, which combines risk likelihood and magnitude to provide an overall risk rating on five levels between very low and very high.
Figure 1: Climate risk scoring system
| Risk magnitude | |||||
|---|---|---|---|---|---|
| Likelihood | 1. Insignificant | 2. Minor | 3. Moderate | 4. Major | 5.Catastrophic |
| 5. Almost certain | M | H | H | VH | VH |
| 4. Probably | L | M | H | VH | VH |
| 4. Possible | L | M | M | H | H |
| 2. Unlikely | VL | L | M | M | H |
| 1. Remote | VL | VL | L | L | M |
Overheating risks
The range of climate risk indicators analysed provide evidence that the frequency and severity of extreme heat occurrences will increase, and that increases will be larger under higher emissions scenarios, and increase over time. With a coastal location, Brighton is shielded from the most severe temperatures projected for the UK, however, temperature and heatwave records are likely to be repeatedly broken, and conditions currently considered extreme will become regular occurrences by the 2050s. As the likelihood of heatwave events, heat health alerts, and frequency of days exceeding various heat thresholds days is projected to increase to 'medium' / 'high', and the magnitude of such events is projected to increase from 'insignificant' to 'moderate', the risk of significant impacts to staff health, wellbeing and productivity are likely to increase. In addition, projections of days where air conditioning is required in order to maintain a comfortable temperature (cooling degree days) show a significant increase under all emissions scenarios.
Table 1 – Summary of heat-related climate risk indicators
| Climate Risk | Climate Risk Indicator (all per year) | Baseline | RCP4.5 2050s | RCP4.5 2080s | RCP8.5 2050s | RCP 8.5 2080s |
|---|---|---|---|---|---|---|
|
Heatwave events | L | M | M | M | M |
| Heat stress (days) | L | L | M | M | M | |
| Amber heat-health alert | L | M | M | M | M | |
| Days per year above 35°C | L | M | M | M | M | |
| Maximum temperature change (°C) | N/A | M | M | M | H | |
| High rail temperatures (days) | M | M | H | M | H | |
| Road melt (days) | L | M | M | M | M | |
| Cooling degree days (annual sum of the number of degrees the daily average temperature is above 22°C each day) | M | M | M | M | H |
Flooding risks
The TPR office is in a location which is at risk from surface water flooding. There will be an increase in both the size and number of extreme rainfall events, and as such the risk from surface water flooding will increase.
Telecom House is not at risk of flooding from surface rivers. However, the site is close to the old course of an intermittent river, the Wellesbourne, which is now completely enclosed within the sewer system. Environment Agency data shows groundwater flooding to be unlikely at the site, however, TPR's Facilities Management note that during particularly heavy rain the water table can rise and cause flooding of the lower floor of the Telecom House car park, which TPR does not occupy, use or lease. Winter rainfall is expected to increase under both emissions scenarios, which may increase the likelihood of these basement flood events.
There is also likely to be an increase in the disruption to travel to and from Telecom House. Both National Highways and National Rail are planning for increased disruption to road and rail travel as a result of both surface water and fluvial flooding, likely increasing the number of days that adverse weather requires employees to work from home. While short-term disruption can be easily managed there is also the potential, in particular on the rail network, for longer-term impacts in the event of significant damage to track.
Flooding and storms both have the potential to increase disruption to supply chains and ICT infrastructure, however, at present the evidence for specific impacts in the UK is unclear. Although TPR does not rely on specialist equipment, and as such there is relative diversity within the supply chain for items such as IT and office equipment, key components such as chip manufacture can be concentrated in particular geographic locations, and as such are at risk of disruption.
Table 2 – Summary of flood-related climate risk indicators
| Climate Risk | Climate Risk Indicator (all per year) | Baseline | RCP4.5 2050s | RCP4.5 2080s | RCP8.5 2050s | RCP 8.5 2080s |
|---|---|---|---|---|---|---|
|
Surface water flooding | M | M | M | M | H |
Water scarcity risks
Whilst annual rainfall is projected to increase by 2080 under RCP 4.5 and RCP 8.5, summer rainfall is projected to decrease by 28.7% (RCP 4.5) and 40.3% (RCP 8.5) by 2080 in Brighton. TPR is located in an area already categorised as under 'serious' water stress, meaning risks to the public water supply, and consequently business operations, may arise as summer rainfall decreases over time.
TPR requires a consistent water supply to the office. However, the volume of water required is not large compared to more water-intensive businesses, or organisations with larger sites. Responsibility for supply also lies with Southern Water, and as such, although a number of water-saving measures are suggested as part of the climate adaptation action plan, water scarcity is not considered a major risk to TPR.
Table 3 – Summary of drought-related climate risk indicators
| Climate Risk | Climate Risk Indicator (all per year) | Baseline | RCP4.5 2050s | RCP4.5 2080s | RCP8.5 2050s | RCP 8.5 2080s |
|---|---|---|---|---|---|---|
|
Annual rainfall (% change) | N/A | VL | VL | VL | VL |
| Summer rainfall (% change) | N/A | L | M | M | H |
Storms and high wind risks
During storms and high winds, wind-blown debris may affect the safety of staff, and in severe cases cause damage to buildings. Brighton currently experiences regular storm impacts, however, significant damage to buildings is rare, with damage more likely to affect transport and energy networks and ICT infrastructure. Network Rail is anticipating an increase in damage and delays caused by storms and high winds.
The current evidence for changes in the strength and frequency of storms and high winds in the UK is limited and is a topic undergoing active research. However, on balance an increase in the frequency and severity of storms is expected. The impact for TPR is likely to be primarily linked to the associated flood risk, and disruption to the transport network (particularly railways), with direct damage to Telecom House considered unlikely.
Table 4 – Summary of storm-related climate risk indicators
| Climate Risk | Climate Risk Indicator (all per year) | Baseline | RCP4.5 2050s | RCP4.5 2080s | RCP8.5 2050s | RCP 8.5 2080s |
|---|---|---|---|---|---|---|
|
Heavy rainfall (mm) | L | L | L | L | L |
| Wind gusts anomaly (m/s) | 0 | No data | No data | VL | VL |
Cold snap opportunities
Minimum winter temperatures are projected to increase by 1.4°C (RCP 4.5) and 3.6°C (RCP 8.5) by 2080 and as a result the number of heating degree days will also decrease. With warmer temperatures expected during the winter months, the number of cold weather alerts is projected to decrease from 2.6 alerts per year in the baseline period, to less than one alert per year on average in 2080s under an RCP 8.5 projection. This presents an opportunity for business operations as heating demand will decrease and present an opportunity for staff health.
It is important to note that the assessment of cold-related impacts does not assume disruption to Atlantic Meridional Overturning Circulation (AMOC). Although AMOC is considered a key tipping point in the climate system, and would cause major disruption to UK weather patterns (including increased risk of extreme cold), the best available scientific understanding is that while there is growing evidence that a slowdown is occurring, a disruptive shutdown remains a low probability event in particular in the period to 2050. However, this will be monitored and addressed in future updates to this strategy, or if there are significant changes in the scientific understanding of the topic. The same applies to other potential 'tipping points' in the climate system – parts of the system where if key thresholds are passed, there is the potential for a rapid and largely irreversible shift to new conditions.
Table 5 – Summary of cold-related climate risk indicators
| Climate Hazard | Climate Risk Indicator | Baseline | RCP4.5 2050s | RCP4.5 2080s | RCP8.5 2050s | RCP 8.5 2080s |
|---|---|---|---|---|---|---|
|
Cold weather alerts (annual) | VL | VL | VL | VL | VL |
|
Heating degree days (annual sum of the number of degrees the daily average temperature is below 15.5°C each day) |
M | M | M | M | M |
| Minimum temperature change (°C) |
0 | L | L | L | L |
Adaptation action plan
Adaptation assessment
The priority risks identified in the risk assessment relate to high temperatures, heavy rainfall and surface water flooding, water scarcity, and storms and high winds. This section identifies the current structures and processes for risk management within TPR and where actions could be implemented to increase the resilience of the organisation. The findings from this adaptation action plan will provide a baseline for climate change risk management within TPR and highlight actions that will increase the resilience of TPR to climate change.
The method for identifying adaptation actions follows the principles in the Estates Adaptation Framework. This includes assessing existing risk management measures and gaps where further measures are needed, and collating and prioritising a list of feasible adaptation strategies. It does not include an economic appraisal of adaptation actions, for example in the form of a multi-criteria assessment. Progress on current adaptation actions has been collected by our consultants through a combination of a desk-based review of the latest regulations, guidance and relevant reports, engagement with selected stakeholders, and a site visit.
Overheating
High temperatures can have significant impacts for an organisation including impacting staff heath, wellbeing and productivity, decreased thermal comfort and an increased need for cooling. Cascading impacts can also result from extreme temperatures such as disruption to energy, ICT and transport infrastructure which impact the operations of an organisation. Below are the current adaptation strategies TPR have in place to manage the impacts from high temperatures and an assessment of the gaps and potential additional actions that could be implemented.
Overall, the office is well-adapted to overheating risks, with good insulation overall throughout the building, and cooling systems in place following a recent refurbishment. There are, however, several operational measures that could be implemented that would strengthen resilience, including the development of specific hot weather working guidelines. The use of home working and providing greater flexibility in working patterns can play a significant role in reducing risks to staff wellbeing and safety but is not a solution appropriate for all employees. This is because residential properties may be more susceptible than an office location to heat risk or may not be well suited to homeworking in general, or because specific mental or physical health requirements mean that working from home is not a suitable option. Developing better understanding of where there are specific needs within the workforce would help ensure comfortable working conditions for all employees.
Current adaptation
- Hybrid working is in place so that staff can work from home in hot weather where appropriate (more comfortable). However, home-working allowances may be used up in the event of prolonged hot weather and will need to be subject to review.
- ICT solutions enable staff to work both in and away from the office.
- The building heating, ventilation and air conditioning systems are in good condition, and modern Variable Refrigerant Flow (VRF) systems provide cooling for the building.
- TPR office space is served by efficient new air conditioning units installed in 2023 which are sufficient for the office size and in good condition.
- The VRF systems also provides mechanical ventilation and supports good indoor air quality.
- The office is well insulated and has fully double-glazed windows.
Gaps
- There is a need to review, and if necessary, bolster specific guidance for staff on safe working during hot weather (whether at home or in the office).
- While the TPR office is currently well-served for cooling, active monitoring of temperature and logging of any overheating incidents could provide early-warning of any issues.
- Specific adjustments for staff with additional cooling needs to facilitate home working.
Additional adaptation
- Hot weather working guidance, potentially including additional home-working provision linked to Met Office heat alerts.
- Support for staff with additional needs for additional cooling for home working as these emerge.
- Active monitoring of office temperatures.
Flooding
Surface water flooding is the predominant source of flood risk to Telecom House, as well as groundwater flooding which has previously affected lower car park levels, which TPR do not lease or use. Risks from flooding include damage to building contents and building fabric. Although TPR office space itself will not be impacted by flooding as it is not on the ground floor, there could be damage to shared building services, and restrictions in accessing the site. Some of the operationally critical equipment housed in the basement plant rooms is raised, while other equipment, such as the switchboard and floor-mounted data racks is not, making them more susceptible to flooding. However, this equipment is located on the first basement floor rather than the lower basement floor. It would therefore take significant flooding (groundwater or surface water) for these to be impacted. While this equipment is not the responsibility of TPR as a tenant in the building, a discussion with the landlord around their preparedness, and potential additional measures, is recommended. There may also be opportunities to add sustainable drainage features to the area outside the building.
Homeworking can again reduce the risk to employees both if the site itself is flooded, as well as during disruption to transport links. A business continuity tool is in place to communicate weather warnings and any disruption to the transport network (weather-related or not). A process is also in place to determine whether the office should be closed for safety reasons, and to communicate this to staff.
Current adaptation
- Hybrid working policies mean that in the event of problems with access to the office staff can effectively work from home, utilising ICT solutions.
- Some basement equipment (such as the generator) is on elevated plinths, therefore providing protection from flooding.
- Extreme weather events and transport disruption is communicated via a business continuity tool.
- Procedure to determine whether the office should close for safety reasons, with closure also communicated via business continuity tool.
Gaps
- Site visit showed that some key equipment in the building basement, (such as the switchboard and some data racks) is not elevated.
Additional adaptation
- Reviewing the siting and protection of key equipment in the basement, and raising, or using door barriers to reduce water ingress during flood events (landlord responsibility).
- Reviewing opportunities for sustainable drainage features, which would also contribute to nature recovery goals (landlord responsibility).
Water scarcity
Water scarcity may be a risk given the location of Telecom House in a water-stressed area and likely increases in water stress as temperatures increase and summer rainfall decreases. Resilient water supply is the responsibility of Southern Water, so recommendations for TPR are focussed on the issue of water efficiency consumption and reducing the impact of TPR's operations on water demand. Water supply during a drought event is beyond TPR's control however there are a range of actions TPR can implement to manage its consumption and promote water efficiency during drought events., Improving water efficiency can help demonstrate that TPR is playing its part, and has links to other GGC priorities, as well as the wider TPR Environment and Climate Change Strategy.
Current adaptation
- Efficient hot water taps in communal areas reduces water wasted in traditional kettles.
Gaps
- Creating a culture of efficient water use.
Additional adaptation
- Aim for a WaterWise water efficiency checkmark for the TPR office.
- Behavioural campaign on water use to staff and fitting of restricted flow appliances.
Storms and high winds
The risks associated with storms and high winds include damage to building fabric from moisture, winds and driving rain, risks to staff health and safety from wind-blown debris, and cascading impacts from disruption to travel, energy and ICT infrastructure. The building fabric appears to be in good condition, and there are no obvious areas in which there are clear deficiencies in building fabric or facades. There is no reported evidence of historic storm damage to the building. The current adaptation strategies offer flexibility to staff and can reduce their exposure to health and safety risks and include a warning system that alerts staff if extreme weather is expected.
Current adaptation
- Building design adequately integrates storm resilience.
- Hybrid working provides some flexibility in the event of severe weather.
- Alerts are sent to staff to warn of extreme weather and transport disruption.
Gaps
- No major gaps identified
Additional adaptation
- There may be a need to consider additional reminders to staff for specific local hazards such as building site debris being blown loose.
Consideration of vulnerable groups
A key consideration for climate adaptation actions is to ensure they do not increase the vulnerability for different groups or individuals. The way in which people experience climate impacts is different between individuals and it is important to recognise the diverse range of needs that individuals and groups may have such as differing mobility, sensory, neurodiversity and health needs. The suitability of adaptation measures should be assessed with careful consideration of how they may impact vulnerable groups to ensure equitable adaptation. Considerations could include:
Engagement:
Consultation with vulnerable groups during the planning process is key to ensuring the outcomes are suited to all users. Involving vulnerable groups throughout the process can lead to an increased sense of ownership and promote the uptake of adaptation measures.
Flexibility:
A degree of adjustment for individuals within the workplace can provide a sense of control over their environment. As part of the fit-out of the new offices at Telecom House, measures were included to support neurodiversity, including colour schemes, finishes / fabrics, lighting and signage, as well as provision of a wellbeing room, a recovery room and a quiet working area. This approach should be continued in the development of adaptation measures.
Communication:
The communication of adaptation plans and measures should be shared in a variety of formats to increase its accessibility. This could include visual guides alongside verbal and written messages. It is also important to ensure that individuals are given sufficient time to process the information and are able to provide feedback about the plans.
Implementation
Based on the risk assessment, and review of adaptation measures, at an overall level TPR as an organisation is well-adapted to climate change risks based on current knowledge and industry practice. The building design and integration of new air conditioning systems significantly reduce the risks associated with overheating, while the organisation's familiarity with working from home utilising ICT provides additional resilience to both site and travel-related disruption from severe weather events and allows business operations to continue with minimal disruption. There are, however, several areas where action could be taken to strengthen resilience, of which resilience to surface water flooding is the most pressing issue.
Due to the nature of TPR as an organisation, and its status as a tenant rather than a landlord, many of the actions outlined below are based on changes to policies and procedures, rather than physical interventions. There are, however, specific areas in which consultation with the landlord of Telecom House is recommended, with the goal of supporting actions to increase the physical resilience of the building itself. Actions below are grouped according to three themes, and have also been categorised according to whether they are immediate priorities, or longer-term actions:
1. Ensuring safe, climate-resilient working
There is an existing system in place to monitor extreme weather, and disruption to public transport (weather or non-weather related) in order to close Telecom House and invoke home working when required. This, together with the physical environment, ICT solutions and attendant working policies, support safe working during extreme events. There are, however, a number of areas where this could be improved, and as such it is recommended that TPR undertake the following activities:
Immediate priorities
- As part of the Equality, Diversity and Inclusion Strategy, or separately, review whether specific groups have differing needs and requirements for climate adaptation, or particular sensitivities to heat that need to be accounted for. Where specific needs are identified ensure that specific plans are in place to support staff and ensure safe, resilient working across all TPR employees.
- Carry out periodic reviews of whether current working practices need to be adjusted to incorporate provisions for extreme weather, including heatwaves or significant flood disruption. With disruptive weather events likely to increase, the objective of these reviews is to ensure that policy doesn’t inadvertently create incentives that increase employee exposure to extremes.
- Ensure that active monitoring of office temperatures is in place, and that complaints related to working conditions being too hot are specifically logged. Linking this data to external air temperatures and weather conditions will provide the evidence needed to establish the key thresholds at which the office becomes uncomfortable. This will allow for early warning of heat-related incidents and establish any trends.
- Review extreme weather working guidelines, and develop guidance on safe working during heatwaves, with a particular focus on how to keep home-working environments cool and accessing the office during hot weather. This guidance can be progressively updated as data on office heat impacts and thresholds is gathered.
- Conduct a review of TPR's service contracts to specifically assess the resilience of suppliers, their vulnerability to extreme events, and their ability to provide uninterrupted services. This could include asking for evidence of organisational climate adaptation plans, risk management processes related to extreme weather events, or commitments to strengthen these processes if they are considered to be inadequate. It is recommended that the review begins with services that are considered critical to TPR operations, such as the resilience of IT and Energy supply. Consider also identifying other potential suppliers and assessing the length of time that TPR could withstand supply chain disruption in different areas.
Longer term actions
- Conduct a periodic review of the latest scientific understanding of climate risks, and in particular those for which there is considerable uncertainty (such as research on storminess), or which are low probability, high impact events (such as a slow-down in ocean circulation mechanisms). This does not need to be carried out on an annual basis, but it is recommended that a review occurs every three years, and can be linked to the process of developing TPR's Climate-Related Financial Disclosure (CFD) report.
- Integrate a monitoring framework for climate resilience into existing business resilience systems to enable the organisation to track progress in adapting to climate change. This should entail a review of data that is already collected, identification of appropriate indicators, and a baseline assessment to determine TPR's current starting point. Disclosure of targets and metrics is recommended as part of CFD reporting, in line with guidance from HM Treasury.
2. Enhancing physical resilience
Although TPR as a tenant is not responsible for the resilience of Telecom House and does not have office space that would be directly impacted by flooding, the adaptation assessment noted several areas in which action by the landlord could increase resilience of the site, and reduce the likelihood of disruption to TPR's business. It is recommended that a dialogue around resilience to flooding is initiated with the landlord, which could be linked to wider discussion of measures to support the decarbonisation of the building. If practical, a coordinated approach considering concerns that other tenants have would be prudent.
Immediate priorities
In particular, TPR should ask the landlord to initiate:
- A review of the siting of key electrical and gas infrastructure and equipment in the basement, and an assessment of whether there is a need for additional flood resistance measures. It should be noted, however, that the equipment is located a floor above the lower basement, thus significant groundwater flooding and/or surface water flooding would be needed for there to be serious impact.
- A review of the opportunities for sustainable drainage features to replace some of the impermeable surfaces that surround the building. This could include, for example, rain gardens, swales, or soakaways, and which could be designed to support biodiversity and contribute to GGC nature recovery goals.
3. A culture of climate resilience
Understanding of the need for climate resilience is relatively under-developed compared to carbon literacy, or appreciation of biodiversity loss and nature recovery needs. While staff awareness on climate resilience does not represent a material risk, there is an opportunity to raise awareness both generally, and within specific teams so that climate resilience can be more widely considered within TPR's actions as a regulator (the Business Resilience Team being a key focus). Initial steps to increase knowledge on climate resilience include:
Immediate priorities
- Using the process of TPR CFD reporting to raise awareness of climate risks within the organisation.
- Explore making optional training on the importance of climate resilience for the financial sector available to staff, and consider whether basic training around climate risks and resilience should form part of the staff induction process.
Longer term actions
Develop an internal campaign focussed on reducing water use within the organisation, and track progress against this. This could include attaining a WaterWise water efficiency checkmark for the TPR office.