Independent Assessment of the Third National Adaptation Programme

2. Strengthening the UK's adaptation plan in the next Parliament

The initial assessment of NAP3 in the previous section highlights that the NAP does not go far enough to ensure that the UK is adequately prepared for climate change. This is true for the climate change already being experienced in the UK today, the climate changes expected over the programme’s lifetime (out to the late 2020s), and the range of further changes possible over decades ahead.

The NAP3 period is critical to building climate resilience in the UK and avoiding lock-in. Reasons for this include:

• By the late 2020s, the global temperature (averaged over many years) will be close to reaching 1.5°C above preindustrial levels, the lower end of the long-term temperature goal of the Paris Agreement. This means that climate-related impacts of a severity and frequency beyond those already experienced will increasingly be felt in the UK by the end of the NAP3 period.^[5]
• Failure to act effectively over the lifetime of this NAP increases the risk of locking-in poorly adapted infrastructure. Significant increases in the investment needed to deliver Net Zero in the UK is required before 2030 (~£50 billion per year additional investment by 2030), and several major regulated infrastructure sectors including energy, water and rail will start new price control periods before the end of the decade. Without effective resilience mandates, the investment made in these price control periods could be misaligned with that needed to accommodate future climate extremes for these long-lived assets.^[6],[7]
• By the end of the NAP3 period, the new Environmental Land Management (ELM) scheme for public subsidies in land management and agriculture will have been rolled-out and target dates under the Environment Act (2021) and Environmental Improvement Plan will be approaching. Improving the health of ecosystems across landscapes, though protection, restoration and sustainable management, over this critical period will help to build ecosystem and hence societal resilience to ongoing climate change.^[8]

Without a strong commitment to a developed and strengthened NAP3 we risk another lost five years of adaptation action which the UK’s people, ecosystems, economy, and infrastructure cannot afford. This promised development and strengthening must now be an urgent priority in the new Parliament following the general election.

In the following two sub-sections we provide advice on two aspects of this strengthening:

• Drawing from international best practice.
• Reforming the UK’s approach to adaptation policy.

2.1 Drawing from international best practice

At the time of the last CCRA, the UK was still regarded as a leader in its approach to climate adaptation. However, progress elsewhere is accelerating whilst our last progress report found some persistent gaps in adaptation planning and a lack of evidence of progress on delivery and implementation across the board in the UK.

International plans and programmes contain examples of best-practice covering all elements of our requirements for a high ambition NAP (Table 2). Whilst the UK has been world-leading on the architecture of how climate risks are assessed and prioritised, the existence of examples for each requirement provides valuable templates for where others have been going beyond what the UK has achieved and show what could and should be achieved in the UK. The government should aim to learn from these, and other international plans, to apply in a UK context as part of strengthening NAP3.

At COP28, the annual conference of parties to the United Nations Framework Convention on Climate Change (UNFCCC), agreement on the framework for the Paris Agreement’s Global Goal on Adaptation was reached (Box 2). Alongside the seven thematic goals – all of which are key aspects of a well-adapted UK, there are four process goals that parties must comply with in the production and delivery of national adaptation strategies.

Despite the UK being an important player in pushing towards a successfully agreed outcome on the Global Goal on Adaptation Framework at COP28, NAP3 is currently falling short of several of these asks – for example there is no ongoing role for a participatory process in NAP3 and a monitoring and evaluation process is not yet in place. Ensuring that NAP3 achieves these, well-ahead of the required 2030 date, should also be incorporated into a strengthening of NAP3. We will also endeavour to ensure that the evidence feeding into the next CCRA (due in 2026/27) will cover all aspects of the Global Goal on Adaptation Framework.

The international climate change negotiations have increasingly recognised the interlinkage between the challenge of addressing climate change and the global challenges of addressing biodiversity loss. For example, the agreed outcome from COP28 recognised the critical role of natural systems in tackling climate change through linking to the 2022 Kunming-Montreal Global Biodiversity Framework and referencing nature-based solutions in the Global Goal on Adaptation outcome. Further developments of NAP3 should seek to integrate with refreshed biodiversity strategies, going beyond the integration between the two agendas present in the current NAP, for example by aligning the UK’s submissions under the UNFCCC and Convention on Biological Diversity, as well as other cross-cutting government agendas such as Net Zero, health and improving infrastructure.^[9]

2.2 Reforming the UK’s approach to adaptation policy

There have now been three NAPs produced under the UK’s Climate Change Act (2008). Similar challenges have been experienced in the first and second cycle (documented in previous Climate Change Committee progress reports) to those encountered in the current version of the NAP. This suggests that achieving the necessary progress on adaptation will require a fundamental repositioning of how adaptation is approached and how it integrates with the wider machinery of government.

Key underlying issues include:

• The current approach to coordinating adaptation is not working. Adaptation policy is currently coordinated across government by the Department for Environment, Food and Rural Affairs (Defra). However, many of the risks that need to be addressed sit with other government departments and local authorities. Despite the best efforts of officials, the machinery of government has been ill-suited to ensure that adaptation reaches the top of other departments’ priority lists and is sufficiently well-understood and resourced in local government. This has been an important factor in the limited success of the NAPs conducted to date and without change it is difficult to imagine future NAPs breaking the cycle of underwhelming policy responses by fostering true ownership of risks across all departments.
• Adaptation in the UK is inadequately funded, and private sector adaptation is poorly understood. The development of the current NAP3 was hampered by poor alignment with the most recent spending review cycle (autumn 2021 – which fixed department budgets out to the end of financial year 2024/25). This limited the ability for ambitious new policy commitments in NAP3 that were not already planned for at the time of the spending review, as well as limiting the potential for large-scale cross-cutting funding of transformative adaptation (such as the Netherland’s Delta Fund). Existing spending commitments on climate resilience are also being eroded by higher levels of inflation, as reported on for flood defences by the National Audit Office. In general, current spending on adaptation from both the public and private sector remains poorly understood in NAP3, and many barriers to private sector adaptation remain that are not effectively tackled by the programme.^[10]
• The frameworks needed to track adaptation and climate risk effectively in the UK have not been put in place. Climate resilience is rising on the agendas of a wide range of organisations. Business, regulators and local government are looking to the NAP to provide clear targets, clear departmental ownership, and standards and metrics for measuring adaptation to help them drive delivery effectively. However, this overarching framework has not been put in place by government, leaving these organisations unclear on their role and how they integrate with others, holding back action. This lack of data collection on relevant adaptation indicators is a regular barrier highlighted by the Climate Change Committee’s adaptation progress reports.

The Committee believes that a refresh and strengthening of NAP3 in the new Parliament is the right time to finally tackle these issues. We identify three key priorities that would help address the major issues and ensure that NAP3 can drive action across government, and beyond, more effectively.

• Reforming governance to put adaptation at the centre of government: the Committee believes that improving the governance of adaptation across government is the main enabler for a strengthened NAP3. Adaptation policy must be reflected in every decision and command the cross-government priority status that it is currently missing. As highlighted by a recent Institute for Government report (Box 3), there are several low-regrets ways to make progress on this, including: a cross-cutting adaptation minister, a joint unit to support adaptation, and further embedding adaptation and resilience into core financial control mechanisms. All of these should be seriously explored for implementation in this NAP programme, alongside considering where responsibility for adaptation might be best placed in government. Improving adaptation governance must no longer be pushed to one side and needs to be addressed now.^[11]
• Aligning further developments of NAP3 with the next spending review: a refresh of NAP3 should be conducted alongside the development of the next multi-year spending review in the new Parliament (likely concluding before end of 2025). This is to ensure that the next spending review can be fully informed on the benefits of adaptation today. Initial work to implement and strengthen NAP3 should focus on better estimation of the amount being spent from public and private sources on climate resilience and how that has changed over time, to support the case for appropriate allocations in the next and future spending reviews.
• Creating accountability with targets and monitoring: a refresh of the NAP should seek to support its high-level vision statement with clear targets and metrics, so that it is meaningful to organisations seeking to understand what role they need to play as part of a wider national effort. The programme to develop indicators to track progress pledged in NAP3 must be accelerated so that it is operational for use in the 2025 Progress Report by the Climate Change Committee. The government should aim to align this framework, where possible, to the monitoring frameworks developed by the Climate Change Committee in its 2023 Progress Report. As part of this effort, the UK Government should seek improved collaboration with the devolved administrations (who are all in the process of developing new national adaptation programmes) on the development and collection of monitoring data to ensure that this is done in a way which maximises benefit across the UK.

These three areas should be top level priorities to help ensure that NAP3 delivers on its commitment to address gaps and raise ambition over the programme lifetime. If the current programme is not developed and strengthened, the UK will be exposed to higher levels of damaging risks from climate change that have the potential to fundamentally compromise aspects of our society if not addressed with urgency. To avoid this, adaptation must now finally be put front and centre of government priorities in the new Parliament.