Climate Change Position Statement

1. Issue identification

Climate change is one of the key global issues of the twenty-first century and is presenting an unprecedented risk to communities. Eight of the 89 risks included in the UK Government’s National Risk Register are identified as climate-change related extreme weather events that are predicted to become more frequent and extreme as global temperatures rise. Extreme weather events include wildfires, storms, high temperatures and heatwaves, low temperatures and snow, coastal, fluvial, and surface water flooding and drought.

Fire and rescue services (FRS) play a key role in responding to climate change related emergencies in the UK. NFCC’s positions and recommendations for change in relation to FRS response to flooding incidents, inland water safety incidents and wildfires are set out in supporting position statements. The focus of this position statement is on the preparedness, resilience, mitigation and adaptation strategies the UK needs to adopt to be prepared to withstand current and future impacts of climate change.

Preparing for climate change impacts is a challenge for FRS and partners within local resilience forums (LRFs)[1] because access to accurate data analysis mechanisms that enable long-term forecasting and detailed risk and impact assessments are limited. Building resilience to climate change requires a longer-term data informed risk planning approach in partnership with LRFs, however LRFs are under-resourced and lack clarity on their climate change resilience role.

A key element of minimising risks and being prepared for climate change impacts is the implementation of long-term mitigation and adaptation strategies. NFCC and FRS are committed to supporting the UK Government to meet sustainability and net zero ambitions, however implementing mitigation and adaptation measures in FRS is costly and requires long-term sustainable capital investment.

Finally, the built environment must be capable of withstanding climate change impacts to protect our communities and to avoid increased operational strain on FRS.

2. NFCC position

NFCC and FRS are concerned that the UK is not adequately prepared for climate change impacts which presents a risk to our communities, our economy, our infrastructure and our national security. Further action needs to be taken to minimise, plan for, adapt and build resilience to climate change impacts to ensure that FRSs and other partners on the frontline of climate change response can develop sufficient preparedness and operational readiness.

FRS exist to reduce risk through prevention, protection and response activities. However, these activities must be delivered in a sustainable way to support efforts to reduce carbon emissions. NFCC and FRS are concerned that FRS do not currently have the investment needed to work in more sustainable ways.

3. Recommendations

NFCC calls on the UK Government and devolved administrations to:

Ensure that there are accurate data analysis mechanisms that enable longer-term forecasting and detailed risk and impact assessments for climate change related incidents at national, regional and in local levels to support Community Risk Management Plans (CRMP) and LRF emergency plans (including equivalent risk assessment plan processes and resilience groups in the devolved nations).
Ensure that FRS have the long-term sustainable capital investment needed to invest in and maintain climate change mitigation and adaptation measures and consider what national oversight and support could be given to FRS to help progress mitigation and adaptation plans in a consistent way across the UK.
Ensure that climate change policy development is integrated and aligned across Government departments and that there is a stronger interface between the national Government, devolved administrations, local authorities, and partner agencies to strengthen partnership working and the ability to share information about climate change risks.
Review the Civil Contingencies Act 2004 and/or the UK Government Resilience Framework and consider what amendments would provide a stronger foundation and appropriate resource for LRF resilience activities in relation to climate change.[2]
Take action to ensure that the UK’s built environment is adapted so that it is capable of withstanding climate change impacts, using methods and approaches that do not compromise fire safety. This includes updating building safety legislation and guidance to reflect the standards new buildings must meet to be resilient to the impacts of climate change and having adequate product testing systems in place to ensure the safe and appropriate use of any products that may be retrofitted onto existing buildings. The product testing regime must be strengthened to ensure suitable standards of manufacture, testing, and quality assurance.
The non-worsening provisions which allow buildings to be refurbished without improvement to fire safety standards should also be disapplied for the purposes of means to escape from fire. As recommended following the Independent Review of Building Regulations and Fire Safety, this would support improvements to fire safety, as more buildings undergo refurbishment to improve their sustainability to minimise environmental impacts and vulnerability to climate change risks.

4. Supporting evidence

How climate change is affecting the UK

Data from the Met Office projects that by 2070 compared to 1990, winters will be between 1 and 4.5°C warmer; winters up to 30% wetter; summers between 1 and 6°C warmer and summers will be up to 60% drier, depending on the region. Weather extremes will become more likely too, with regions in the south of England projected to experience temperatures reaching 40°C and increased rainfall by up to 25%. The extent of climate change will depend on how much we can limit global emissions over the coming decades.

The impacts of climate change are already impacting across all of the UK, however climate change impacts unique to each of the four UK nations are set out in the national summary documents published by UK Climate Risk to underpin the UK Climate Risk Independent Assessment (CCRA3).

Socially vulnerable groups will be impacted more than others by climate change. Socially vulnerable groups include, for example, people in poor health or who are disabled, older people and people living in areas which are at increased risk of climate impacts such as floods and heatwaves, The UK population is growing and the number of people aged 65 years and over is expected to be 19.8 million by 2069, accounting for 26.2% of the projected population.

FRS capabilities will need to grow as the impacts of climate change increase. Climate change impacts are expected to result in areas of the world becoming uninhabitable by 2050, meaning population migration is likely to result in higher population density in particular areas of the UK, increasing operational burden on FRS which serve densely populated areas.

FRS activities to respond to and minimise the impacts of climate change

As a Category 1 Responder[3] under the Civil Contingencies Act 2004, FRS play a key role in responding to extreme weather events as a consequence of climate change. Individual FRS are also statutory members of their LRF and have long-standing relationships with local partners which work collaboratively to plan for and respond to extreme weather events. Currently, under the Fire and Rescue National Framework for England, FRS are required to develop CRMPs, which are typically short to medium-term four-year plans that identify how community risks will be prevented and responded to.

However, there is a need to shift to longer-term thinking on risk management planning when considering climate change impacts. This could be achieved by adding an additional component, separate but complementary to the CRMP planning process that requires FRS to analyse risks to local communities over a longer-term horizon, for example 20–50 years, using data-informed approaches as set out below. This will help to ensure that actions taken now to prevent and mitigate against risks in local areas are sustainable and create better outcomes for communities in the longer-term. A methodology to support FRS to undertake an additional CRMP longer-term horizon risk analysis activity would be valuable and ensure a consistent approach is adopted nationally.

Effectively preparing for the risks and impacts of climate change will require data-informed approaches. Data analysis of FRS attendance at climate change-related incidents captured in the Home Office Incident Recording System (IRS) should provide an understanding of trends, whilst data from other sources is capable of providing information about future anticipated climate change impacts in FRS local areas. Supporting FRS partnerships with academic institutions, the Met Office and the Climate Change Committee (CCC) would be valuable. FRS, whilst expert in emergency planning and response, require more sophisticated data analysis and data science skills for predictive modelling to understand risks and impacts in local areas which could be provided via such partnerships.

Raising public awareness and improving public education on the risks that could result from climate change impacts, and how to avoid them, is central to FRS prevention work in local communities. Influencing how the public behaves in an environment where risks are exacerbated because of climate change impacts is an important part of prevention activity. For example, irresponsible use of barbeques can result in wildfires and cooling off in water in hot summer temperatures comes with water safety risks. Consistent and timely public awareness and education campaigns delivered at a national level would support local initiatives and campaigns aimed at reducing the impacts of climate change.

Furthermore, in a world where green technologies are being increasingly introduced to help to meet net-zero objectives, FRS play an important role in educating communities on fire risks, including, for example, those which arise from lithium-ion batteries found in e-bikes, e-scooters and many other common household products.

The need for FRS to invest in climate change mitigation and adaptation strategies in parallel

It is important to make the distinction between being operationally prepared to respond to extreme weather events and the longer-term strategies needed to adapt to and mitigate the longer-term trends that climate change will bring when the extraordinary becomes ordinary.

The Climate Change Act 2008 commits the UK government to reduce greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050. NFCC and FRS are supportive of the Government’s ambition to reach net zero by 2050 to limit global warming and resultant climate change, and, alongside all public sector organisations, have a legal duty to take action.

Adaptation measures address the impacts of climate change whilst mitigation measures address the causes of climate change. Both mitigation and adaptation measures are needed to tackle climate change and will be more impactful when planned and implemented together. Any investment into adaptation and mitigation plans now will save money in the longer term. However, investing in change to adapt to and mitigate the effects of climate change is costly for FRS and any funding needs to be long term and sustainable. Whilst many FRS are doing what they can to work in more sustainable ways and build resilience to climate change impacts within the communities they serve, funding limitations often hinder the ability of FRS to invest in renewable energy sources for electricity, heating and fleet.

Changes to vehicles, buildings, and operating procedures all require investment, but this is difficult to justify in the face of real-terms funding cuts and the need to resource statutory responsibilities. Capital investments are particularly challenging to implement, and green alternatives can be more expensive. Alternatives to diesel vehicles pose a particular challenge, as procuring new vehicles and installing appropriate charging infrastructure is costly, and must in itself be planned safely to protect FRS critical infrastructure against increased fire risks associated with EV chargepoints. With national plans to ban sales of new petrol and diesel vehicles by 2030, it is important that FRS are granted appropriate investment that enables FRS to transition to the safe use of alternative electric vehicles.

Some FRS employ and work with a wide range of skilled individuals who can support the delivery of effective environmental and sustainability action, including the implementation of mitigation and adaptation strategies. Some FRS have also taken advantage of grants available to support environment sustainability projects. However, with resource and funding limitations, there is no consistency in approach across UK FRS to progressing mitigation and adaptation plans.

National oversight and support which includes establishing baselines, monitoring progress against agreed targets, identifying and sharing best practices and providing tailored practical support to individual FRS would be valuable.

FRS have a critical role in building resilience to climate change impacts

FRS prevention, protection and response capabilities are often, but not always, underpinned by statutory responsibilities and funding. All FRS activities, but particularly prevention activities, are key to building resilience to climate change-related risks. Reducing the impacts of climate change-related events on people and communities is going to become increasingly important.

To further enable FRS to undertake activities which help to build community resilience, it will be important that the Government has a clear national vision of what a resilient UK looks like, with coordination between departments to enable a more integrated approach to climate adaptation through coordinated policy making. In its recent review of the UK’s third National Adaptation Programme, the CCC identified that Government adaptation policy must be reorganised so that it becomes a fundamental aspect of policy-making across all departments, links with government spending reviews, and is integrated into other key priorities such as nature restoration, infrastructure development, net zero, and health.

In addition, resilience in the face of more frequent and severe extreme weather events will require a stronger interface between the national Government, local authorities, and partner agencies. Greater collaboration could ensure that intelligence on data trends, forecasting models and risk information is shared, facilitate more effective pre-planning and prevention work, and assure the Government that local plans are underpinned by a coordinated and shared understanding of risk. Intelligence on data trends, forecasting models and risk information collected at local levels could also inform national resilience planning.

Currently, LRFs maintain, test and exercise plans linked to the effects of climate change. As an LRF partner, FRS play a key leadership role in building and supporting community resilience to climate change impacts and supporting sustainable ways of living. This includes, for example, FRS identifying those in communities who are most vulnerable to climate change risks and impacts and working with those individuals to raise awareness of those risks and how to mitigate them. This FRS prevention and mitigation work is an essential upstream way of working to minimise risks and impacts which can be costly in recovery following a climate change-related incident. However, LRF resources are limited and there is a lack of clarity on the role of the LRF in relation to climate change resilience activities.

Clarifying the roles of individual LRF partners in relation to climate change resilience and agreeing what intelligence should be shared within the LRF to inform climate change community resilience plans would be valuable. This would set the foundations for more structured LRF intelligence-sharing processes and partnership approaches to climate change community resilience actions in the future.

FRS protection role and the importance of adapting the built environment

FRS also have an important protection role in improving the safety and wellbeing of communities by reducing risks and incidents in the built environment. Protection is the work FRS do to improve safety in the built environment, which includes enforcing fire safety legislation and providing advice and guidance on building safety. FRS also raise potential fire safety risks via Building Regulations consultations and, in England, as members of Building Safety Regulator (BSR) multi-disciplinary teams.

In its March 2023 ‘Progress in adapting to climate change’ report to Parliament, the UK CCC sets out progress made against three top-level outcomes that need to be achieved to ensure that buildings, including residential, commercial and public buildings, such as schools, prisons and hospitals, are resilient to climate change impacts. These include that buildings do not overheat, that they are prepared for flooding, and that they are resilient to other climate risks such as subsidence due to drought and dry soil, or structural damage due to high winds. The CCC makes several recommendations to meet these outcomes and highlights that an additional outcome relevant to progressing adaptation efforts is ensuring building safety, including meeting fire safety standards.

NFCC and FRS agree that buildings should be adapted to be able to withstand climate change impacts. If action is not taken, communities will be at risk and FRS are at risk of increased operational burden. However, any adaptation measures taken must not compromise fire safety and NFCC urges caution when using new or relatively unregulated and untested products. Any new construction materials should undergo whole-system testing to ensure fire safety standards are not adversely affected.

Planners have long had a role in ensuring that new developments take account of climate change adaptation. A revised National Policy Planning Framework was released in 2023, which notes that all building plans “should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures.”

However, the Building Regulations 2010 in England, and supporting statutory guidance (the Approved Documents) are yet to reference and embed best practices in relation to climate change in new residential buildings. NFCC therefore recommends that legislation and statutory guidance be updated to ensure climate change matters are safely and appropriately incorporated.

The Grenfell Tower Inquiry’s Phase 2 report has called for significant changes to the building control process and, notably, a “construction regulator, reporting to a single Secretary of State.” A revision of the current system of Building Regulations seems an ample opportunity to consider the possible future impacts of climate change in relation to new builds.

We would like to see this mirrored for existing buildings too, to ensure that retrospective work on buildings, including any retrofitting, refurbishments, change of use, or remediation are able to comply with the functional requirements.

Non-worsening provisions allow buildings to be refurbished many times without improvement to fire safety standards. The Independent Review of Building Regulations and Fire Safety that was carried out following the Grenfell Tower Fire, found that whilst there is a rationale for not imposing the latest modern building standards on old buildings (which may quickly make continued occupation, or any refurbishment activity uneconomical), large numbers of existing buildings have increasingly out-of-date fire safety precautions. The review found there is also the potential for some refurbishment work to escape the net of scrutiny and be carried out in such a way as to compromise the fire safety of the building.

As more buildings carry out retrospective works to support sustainability such as improved heat efficiency, this risk may increase. NFCC therefore recommends the disapplication of section 4(3) of the Building Regulations, and an uplift to Article 38 of the Regulatory Reform (Fire Safety) Order 2005.

Improved alignment and integration of climate change adaptation measures across relevant building safety regulatory strategies would be an opportunity to ensure that climate change adaptation measures are implemented simultaneously with building safety measures.

Footnotes

[1] Or equivalents in Scotland and Northern Ireland. There are 38 LRFs in England, and four LRFs in Wales, There are 3 Regional Resilience Partnerships (RRPs) in Scotland and Emergency Preparedness Groups (EPGs) in Northern Ireland.

[2] To include any relevant legislation, regulations or guidance specific to LRF equivalents in Scotland and Northern Ireland, for example the Civil Contingencies Act 2004 (Contingency Planning (Scotland) Regulations 2005 and Guidance for Scotland’s Regional Resilience Partnerships on Risk and Preparedness Assessments and the Northern Ireland Civil Contingencies Framework document.

[3] Whilst Northern Ireland FRS is not a Category 1 responder under the Civil Contingencies Act 2004, equivalent duties are set out in the Northern Ireland Civil Contingencies Framework document.

References

Equalities Impact Assessment

Climate Change Position Statement Equalities Impact Assessment