Well-adapted digital and telecoms system

Risk to the system from climate change: flooding, heat, high winds, and drought impact the digital and telecoms system.

Objective

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Data centres and telecoms maintain continuity of service for emergency services and critical infrastructure.

Proposed target: from now through to 2050, there should be no losses of service to CNI functions, including emergency calls, due to climate-related hazards.

Actions

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Physical adaptation of assets: infrastructure siting and protection from flooding and wind, uptake of fibre-based digital systems, and water efficient cooling systems for data centres.

Infrastructure siting and protection from flooding and wind: site selection and physical measures such as equipment elevation, flood defences, and improved drainage, including sustainable drainage systems, can reduce vulnerability to flooding for both data centres and telecoms. Actions such as strengthening mobile masts and towers, or tensioning, rerouting or undergrounding cables, can reduce telecoms vulnerability to high winds.
Fibre rollout reduces flood risk to telecoms: the switchover from the Public Switched Telephone Network (PSTN) to fibre-based digital systems will be completed by January 2027. It will reduce flood vulnerability in the telecoms system. Fibre is inherently water resistant and only requires power at each end of the line rather than along the line (as is the case for the PSTN) – reducing susceptibility from water ingress. Fibre is also more resistant to extreme temperatures.
Cooling systems designed to withstand extreme heat: to maintain continuity of service, data centres serving CNI functions will increasingly have to adopt cooling systems. These need to be capable of withstanding temperature extremes expected at 2ºC of global warming through to 2050.
Reduce water demand: data centres can reduce their vulnerability to water shortages by adopting more water efficient cooling systems, storing water, re-using treated wastewater, and integrating onsite water harvesting.

These adaptation actions are connected with adaptation in the water and wastewater system, and in the built environment and communities system.

Redundancy of inputs and services: backup power and batteries at vulnerable assets and premises, multiple wired connections for critical key assets, redundancy in cooling capacity, alternative water supplies for critical data centres, multiple telecoms networks via competing suppliers, and data storage redundancy.

Power supply redundancy: for data centres, actions include backup generators, onsite batteries and solar, as well as providing entirely independent grid connections. For telecoms, this includes backup generators and batteries at key nodes in the network, such as masts and street cabinets, as well as in-home batteries for vulnerable customers.
Redundancy for other key inputs: as well as providing backup power supply, data centre and telecoms providers also make use of redundancy for other key inputs. For instance, for cooling, water supply, and network connections, including multiple fibre connections.
Telecoms network redundancy: the main source of telecoms redundancy comes from most users being able to access services via several separate networks. This includes landline customers able to access mobile services when the landline is unavailable, or vice-versa. It also includes mobile customers being able to access another mobile network if their service providers’ is unavailable. Satellite services offer further resilience.
Data storage redundancy: redundancy in customer data storage behaviour can reduce the impact of data centre outages. For example, customers can save key data in more than one location.

These adaptation actions are connected with adaptation in the energy system, and in the water and wastewater system.

Enablers

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Clear plans, roles, and responsibilities: confirming the extension Ofcom’s resilience mandate to cover data centres, and effective coordination between the digital and telecoms industry and the energy sector.

Given the key dependency on the power system, effective coordination and engagement with the energy sector is critical for effective functioning of telecoms and data centres. The Electronic Communications Resilience and Response Group (EC-RRG) is a valuable cross-government and telecoms industry forum to promote resilience. Currently, Distribution Network Operator’s cannot give telecoms networks priority for restoring power supply following an outage. The UK Government is set to develop guidance to electricity network operators on the restoration of CNI customers following unplanned events. It will also consider whether legislative or regulatory changes are needed.

Data and monitoring processes: enhanced reporting of climate-related incidents and adaptation plans for assessing climate risk and informing market choice.

Enhanced reporting of climate-related incidents affecting CNI functions and adaptation plans would enable regulators and the market to identify and respond effectively to climate risks. While the digital and telecoms sector has a mature understanding of resilience issues, understanding of how climate change affects these is relatively nascent. For example, whether increased storminess affects the duration of power outages and, therefore, battery-back up requirements. Adaptation reporting is limited and, for telecoms operators, often on a confidential basis. To date, Adaptation Reporting Power (ARP) submissions have been received from the regulator, a small number of trade organisations, and a limited set of operators. ARP reporting currently covers telecoms operations (although individual operator returns are voluntary and confidential) and does not extend to data centres. Available evidence is typically high-level and qualitative.

Policies

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Regulation: to enforce service standards, shape investment priorities and provide guidance on key resilience issues.

Ofcom regulates the telecoms sector in the UK and is expected to assume a regulatory role for large data centres in future. Ofcom’s periodic reviews of telecoms markets shape investment priorities and competition and provides guidance on key issues. Ofcom has recently issued resilience guidance for telecoms providers that included network redundancy, traffic prioritisation, and incident reporting.

Legislation: to clarify responsibility of telecoms and data centres and provide frameworks on managing climate risks.

Confirming data centres and climate resilience as part of Ofcom’s mandate would help strengthen oversight of climate risks and support the implementation of key adaptation actions, for example through guidance. Part of Ofcom’s remit is to oversee resilience of the telecoms sector. They have provided valuable guidance on resilience measures, including for several climate change risks. However, Ofcom does not currently have regulatory oversight of data centres, which is expected to be confirmed by the Cyber Security and Resilience Bill. Separately, clarifying that Ofcom’s resilience mandate explicitly includes climate change hazards would help ensure sufficient oversight and guidance to manage climate risk in the sector.

Reporting requirements: for providers of critical services to improve oversight and market knowledge of climate risks.

This could be achieved by compelling providers to respond under the Adaptation Reporting Power, which has seen limited voluntary responses from the sector to date. Doing so would require legislation. To track progress towards our suggested target requires reporting of climate-related incidents to CNI functions within the digital and telecoms sector. The appropriate means of reporting will need to be carefully considered given the sensitivity of such information.