Consultation outcome

Summary of responses and government response

Updated 17 July 2023

Introduction

The Adaptation Reporting Power (ARP) was introduced under the Climate Change Act 2008 (the CCA 2008). It provides for infrastructure operators and public bodies to report on how they are addressing current and future climate impacts.

Under the 5-yearly cycle of the CCA 2008, the government is required to set out and consult on its strategy for reporting. This strategy is required to be laid in Parliament alongside the National Adaptation Programme, in this case the third National Adaptation Programme (NAP3) which is expected later this year.

Purpose and scope of the consultation

On 22 February 2023 the government published its consultation on the proposals for the fourth round of reporting under ARP. In the fourth round of reporting the government is proposing to make changes to the timing of the reporting cycle, improving the alignment of adaptation reporting with other elements of the associated statutory framework for climate change adaptation. To achieve this, the closing date for the next cycle of reporting would need to be brought forward to late 2024 (from 2026). After this, reporting would return to its 5-yearly cycle. This change would mean that adaptation reports can be used in the government’s Climate Change Risk Assessments and NAP more effectively in future.

In recognition of the fact that this change would make the reporting window for round 4 shorter than in previous rounds, we proposed to keep most other elements of the reporting strategy broadly consistent with round 3. A more comprehensive review of adaptation reporting was proposed to take place in advance of round 5. The aim of this would be to ensure the process remains fit for purpose in driving action on adaptation and informing government on the climate change preparedness of infrastructure sectors.

Following the close of round 3 at the end of 2021, there has been a period of ongoing engagement with stakeholders, including through the Climate Change Committee’s (CCC) independent evaluation published in July 2022. This allowed views to be reflected in the formulation of the government’s approach for consultation. The formal consultation was open to all members of the public from 22 February 2023 and was proactively disseminated to reporting bodies and target sectors. It closed after 6 weeks, on 5 April 2023.

76 consultation responses were received, of which 62 were submitted through an online portal and 14 by email. Only one response was submitted by an individual (rather than an organisation), and 2 responses were submitted jointly by multiple organisations. The joint responses would have a small effect on some of the very close results, if their composite organisations had been counted as separate votes. This is explained where relevant below. Additionally, several responses came from organisations representing many members. We have not considered the size of their membership in this analysis.

Of the 62 responses on the online portal, 10 requested to remain anonymous. None of the 14 respondents by email asked to remain anonymous. Organisations who responded (and not individuals) are listed in Annex A.

Responses received to each question

In general, the responses to the consultation endorsed the proposed approach to the strategy for the fourth round of reporting under ARP (ARP4).

There was overwhelming support (97%) for the principles and objectives for reporting and the proposed changes to the timescale. On the question of whether reporting should be mandatory or voluntary, there was no overall majority in favour of either position. The largest number of responses (33, representing 48.5% of the total) were in favour of mandatory reporting, either outright or in principle. 16 (23.5%) were in favour of voluntary reporting (2 of which were joint responses covering 5 separate organisations) and 19 (28%) were undecided. However, a large proportion of those in favour of mandatory reporting (27% of the 33 responses) caveated their responses, citing practical challenges for government and industry in implementing it in the shortened timeframe. Many noted that mandatory reporting may be more appropriate from round 5 onwards.

Respondents supported greater alignment with other reporting regimes. They also supported maintaining a case-by-case approach to sectoral reporting (62%). They were supportive of and provided helpful advice on reporting by regulators and on enhancing reporting on interdependencies and cascading risks.

Most respondents (70%) believed reporting templates are helpful but recommended their use be voluntary and supplemented by guidance. 67% agreed that updates to existing risk assessments made sense for those who reported in round 3, and 69% favoured a standardised approach to risk assessment.

A majority (63%) of respondents agreed with the proposed expansion of scope, in line with the CCC recommendations. There was broad support for a pilot of reporting by Local Authorities. No respondents objected to the approach to devolved and reserved matters. Helpful information was provided by respondents on the costs and benefits of reporting and future reviews of adaptation reporting.

The responses to the questions in each of these areas are summarised below.

Objectives for the fourth round of adaptation reporting

The government proposed that the primary of objectives for ARP4 should remain to:

1. support the integration of climate change risk management into the work of reporting organisations
2. build understanding of the level of preparedness of key sectors to climate change, at a sectoral and national level, and inform other parts of the government’s statutory cycle for climate adaptation, including Climate Change Risk Assessments (CCRAs) and National Adaptation Programmes (NAPs)

To support the second objective, government proposed for round 4 to operate on a shortened timescale with a closing date of late 2024. On this timescale, round 4 reports would be produced in time to be factored into the CCC’s independent advice to government, ahead of the publication of the next UK Climate Change Risk Assessment.

It was also proposed that reporting should focus on changes since round 3, such as any significant changes to the risk assessment, the latest progress, and any new action needed. As such, government proposed the following principles for reporting:

1. reporting should be proportionate, risk-based and streamlined to minimise burdens or duplication
2. reporting should build on previous rounds of reporting to improve report quality where appropriate, and participation

Respondents were strongly in favour of the objectives and principles as set out below. They believed these were consistent with the shortened timeline for ARP4 and made suggestions on how to further streamline the reporting process.

1. Do you agree with the objectives and principles for this round of reporting? Please give your reasons as necessary.

There were 73 responses to this question, of which 71 (97%) agreed with the proposed objectives and principles for reporting. Points made in support included:

• a shortened reporting window for round 4 is sensible as it will improve alignment with other statutory documents, including CCRA, NAP and CCC’s independent advice to government going forward
• the objectives and principles are commensurate with the shortened timings of ARP4 and will ensure that reporting is proportionate and risk-based
• reporting teams will only have a year instead of the usual 3 to prepare and proposed approach reduces their workload
• the principles address barriers that prevented area-based organisations from reporting previously

Further points were made by respondents who supported the principles and objectives, and advocated for further nuancing, including:

• it should be stated more clearly that ARP4 reports are considered ‘interim’
• Defra could provide guidance on what constitutes ‘significant changes’ to ensure proportionate reporting
• ARP4 can be further streamlined and align with other reporting requirements
• the objectives should reflect ARP’s role to drive action on climate adaptation rather than merely as a reporting mechanism, and to promote action by the general public and private sector to promote climate resilience
• reporting in certain sectors could be staggered to give regulators the opportunity to review reports before submitting their own

There were 2 dissenting responses, one of which noted that while the principle of proportionate reporting is sensible, the outputs of ARP4 would only be useful for UK’s fourth Climate Change Risk Assessment (CCRA4) if every organisation followed, as far as possible, a consistent set of requirements. The other response made no further comments.

2. Are there any additional objectives or principles you would want to see included?

There were 32 responses to this question. Recurring themes to the suggestions are listed below. Brackets show where certain themes will be expanded on in later questions.

• include an objective on long term climate resilience (read ‘Evidence and risk assessment’)
• set out the fundamental aim that organisations need to deliver credible plans to ensure their services are resilient to the effects of climate change (read ‘Guidance and templates’)
• include more references to failures that are systemic and cascade across sectors (read ‘Reporting on interdependencies and cascading risks’)
• be more transparent about areas where there is a lack of progress
• expand the second principle to include industry or sector-led programmes to assess climate risks and adaptation
• include greater consideration of the CCRA3 principles of good adaptation
• take better account of sector-specific conditions
• set out how ARP4 aligns with NAP and how it supports the delivery of other programmes such as Net Zero Strategy and Environmental Improvement Plan
• focus reporting on actions taken both in response to recent extreme climate events and to address gaps identified in ARP3 (read ‘Evidence and risk assessment’)
• set out a requirement to communicate ARP4 objectives and principles to relevant audiences
• set out that reporting should be mandatory (read ‘The requirement to report’)

3. Would providing an update on changes since round three of reporting enable your organisation to deliver a report within a shorter time period?

This question was answered by 71 respondents, of whom 29 noted they did not participate in the third round of reporting. Of the 42 respondents who did, 30 (71%) answered yes, 8 (19%) were unsure and 4 (10%) said no.

It was noted in support that:

• ‘light touch reporting’ based on updating progress since ARP3 is appropriate and consistent with timings
• alignment with other reporting, such as that recommended by the Taskforce for Climate-related Financials Disclosures (TCFD) will further reduce workload
• reduced reporting burden for ARP4 gives room for all reporting organisations to develop detailed climate risk assessments, taking account of interdependent risks, for the fifth round of adaptation reporting assumed to be due in 2029

However, there were also challenges that will potentially increase the time and resources needed including:

• some organisations are in the process of updating the methods or scope of their climate risk assessments
• inclusion of additional requirements on the level of evidence
• further alignment with sector-specific statutory or non-statutory reporting would be preferred

It was also noted repeatedly that Defra should provide clear guidance on what is meant by ‘light touch reporting’ so organisations can have a better idea of the amount of resource required and to avoid being penalised for undersupplying evidence.

4. Do you have any further proposals that would help streamline and minimise the reporting burden on your organisation or sector?

Answers to this question came forward from 41 (55%) of the respondents. Comments included:

• there should be no additional reporting requirements compared to ARP3
• there should be clear guidance and examples of best practice to improve consistency
• in addition to guidance, a standardised template should be trialled to provide even greater consistency and clarity on information required
• there should be a clear point of contact in government who is available to advise as organisations prepare their reports
• organisations should be encouraged to make their reports more accessible, for example by creating a customer-facing version of the main report
• reporting deadlines should not be in the first half of the year to avoid clashing with the end of the financial year
• engage with sector-specific industry groups, such as the Energy Networks Association, to ensure intra-sector collaboration and standardisation
• provide feedback on lessons learned from ARP3 and highlight areas that Defra is not expecting any information on in ARP4
• provide sector-specific climate risk models
• clearly set out the purpose of reports and how they will be used (one respondent said they were surprised by follow up questions on their ARP mitigation proposals)
• additional training on climate change risk assessments and creating adaptation plans would be helpful for some organisations
• ARP4 reports will feed in directly to CCRA4 and NAP rather than duplicating the collection of similar evidence later on

An additional comment noted that ‘there is no short cut to producing a thorough analysis of climate related risks and adaptation plans for the reporting organisations.’

The requirement to report

Questions in this section elicited a range of views. Respondents noted that mandatory reporting is just one way to encourage organisations to implement adaptive measures. Respondents also queried what mandatory reporting would look like for first-time participants, as they would have no prior plans to update on and will have to decide between undertaking a full climate risk assessment within the shortened timeframe or delay until the next round.

The consensus view that has emerged is that ARP reporting should be kept voluntary in round 4 but made mandatory in round 5. Several responses suggested that this is the sensible approach that balances the urgency of taking action to address climate risk against the practicalities and reporting burden. For example, it was noted that even if arguments favoured a mandatory approach, the timings between now and the proposed 2024 deadline are likely to make it unpracticable. Arm’s Length Bodies who responded noted that they understand the challenges of mandatory reporting and are eager to provide support to responding organisations.

If government does decide to make reporting mandatory in round 5 then some respondents believed that it should announce this intention as the fourth round of reporting gets underway. Their view was that this would send a strong signal and even encourage some organisations who had not originally planned to report under the fourth round to do so in order to familiarise themselves with the process.

Respondents also noted that it would be important to set out what mandatory reporting would mean in practice. It was repeatedly suggested that government guidance and templates will be important parts of this. There were also suggestions that a well-designed template can enable a blended approach whereby some sections are mandatory while others are voluntary. Similarly, many responses noted that organisations that are responsible for national infrastructure or are otherwise critical for their sector should face a higher burden to respond than smaller, less systemically important ones. Additionally, some respondents were of the view that voluntary reporting from organisations outside the defined scope should continue even if reporting from organisations within scope is made mandatory.

5. Should ARP reporting remain voluntary or be made mandatory in round four? Please give your reasons as necessary.

There were 68 responses to this question, with no overall majority on either side. 39 (57%) responses came from existing reporting bodies. The largest number of responses (33, representing 48.5% of the total) were in favour of mandatory reporting, either outright or in principle. 16 (23.5%) responses were in favour of voluntary reporting (2 of which were joint responses covering 5 separate organisations). 19 (28%) were either undecided (or did not take a view) or provided text-based answers that can most closely be described as undecided (or did not take a view). However, a large proportion of those in favour of mandatory reporting (27% of the 33) caveated their responses, citing practical challenges for government and industry in implementing it in the shortened timeframe. Many noted that mandatory reporting may be more appropriate from round 5 onwards. Among the 39 existing reporting bodies that responded to this question, 12 favoured voluntary reporting, 14 preferred mandatory and the remaining 13 suggested a mixed approach, were undecided or did not take a view.

Reasons given in support of ARP reporting remaining voluntary included:

• unless very detailed standards and guidance are provided, making reporting mandatory may cause organisations to respond with reports that are unhelpful in assessing progress
• many organisations do not have adequate resourcing to comply, and making reporting mandatory may divert resources from other important areas
• many public sector organisations, particularly local authorities, would be reporting for the first time in ARP4, and the flexibility of voluntary reporting will ensure only the right information is gathered
• making reporting mandatory under round 4 risks organisations approaching it as a ‘tick box exercise’

Reasons given for making it mandatory included:

• it will help organisations to understand what other organisations in their sector are doing and encourage knowledge sharing and collaboration
• it will help us understand the state of adaptation and resilience across sectors and better address interdependent risks
• it can offer legitimacy to much-needed adaptation progress
• 2 rounds of voluntarily reporting have failed to provide the right incentives for organisations to allocate resources to adapting to climate change where actions are not currently commensurate with the risks posed
• not enough organisations, both private and public, treat adaptation planning and reporting as a priority and take-up on voluntary reporting is not high enough (approximately 20% of invited organisations in the last round of reporting did not submit a voluntary return, according to the CCC)
• engagement with ARP has decreased and can be corrected by making reporting mandatory (approximately half of organisations who did not report in ARP3 had done so in previous rounds, according to the CCC)
• keeping ARP4 reporting voluntary carries the risk of decreasing the pool of reporting organisations, as the shortened timeline of ARP4 will mostly elicit updates from organisations who have reported under ARP3
• it is particularly important for organisations that are public bodies or are judged to provide critical infrastructure to report on their progress

Reasoning from respondents who were undecided included:

• if information generated from voluntary ARP reporting is sufficient to generate a robust view of industry progress then it should be kept voluntary, but vice versa
• reporting should be made mandatory if an organisation has adequate resourcing and standardised reporting mechanisms
• smaller organisations can produce reports voluntarily even as larger ones are mandated to generate them
• value gained from mandatory reporting should be balanced against the value from wide active participation through a voluntary process
• organisations that are already subject to Task Force on Climate-Related Financial Disclosures (TCFD) should report mandatorily

6. Should the position be reviewed again ahead of round five?

70 respondents answer this question and of those 53 (76%) favoured reviewing the nature of reporting again ahead of round 5, compared to 8 (11%) who did not want it reviewed. 9 (13%) respondents were undecided or provided text-based answers indicating they were undecided.

7. What impacts, positive or negative, could mandatory reporting have in your organisation?

65 respondents answer this question. In addition to points already summarised under question 5, these points were noted:

Positive impact of mandatory reporting:

• it would empower teams in organisations that are responsible for delivering adaptive action, raise their profile and drive further resource allocation
• it would further integrate climate change risk management into the organisation’s decision-making process

Negative impact of mandatory reporting:

• a sense that reporting is compelled rather than a voluntary participatory process
• additional strain on resources (one respondent who is an industry association said they could only support mandatory reporting if it came with financial assistance)

• quality of reporting may decrease if the requirement of reporting is quantitatively high

• the potential exposure of confidential, commercially-sensitive and security sensitive information

Many respondents noted that they already treated reporting as mandatory in all previous rounds so changing the approach would not cause a material difference. A few responses also noted that they wish to see more feedback from previous rounds of ARP in order to demonstrate its value.

8. What else can government do to encourage additional coverage in sectors where gaps have been identified? How should we determine proportionality in these sectors?

53 respondents commented on this question. Many suggestions for how government can encourage additional coverage were made, including:

• directly engage with sectors where there are gaps through trade and professional bodies to explain the importance and benefits of participating in ARP

• provide grant funding for ARP reporting, especially for organisations that have not previously reported
• provide funding to help organisations address gaps identified through ARP
• share best practice and examples of good implementation plans
• provide additional support on how to assess and monitor progress

• include greater consideration of supply chain risks

• be clearer on risk factoring and appropriate use of different global warming scenarios
• encourage individual organisations rather than sector organisations or bodies to respond as they are the real owners of levers that can address climate change
• link financial incentives (for example on funding to support implementation) to reporting
• publish names of organisations who are within the desired scope but have not previously voluntarily provided a report

• investigate barriers in low reporting sectors

• give organisations that have the greatest capacity to report in different sectors an additional leadership responsibility to encourage non-responders
• direct all organisations to complete a mandatory but streamlined ‘checklist’ to ascertain a baseline set of data, in addition to the full ARP process
• use ARP4 to gather better information on costs of reporting and pursuing adaptive actions to demonstrate their benefits
• seek more broadly to encourage all organisations to prepare adaptation plans, whether or not they fall in scope of ARP

Respondents engaged with the question on proportionality sparingly but there were suggestions that priority should be given to areas most exposed to climate risks, low ability for the relevant organisation to respond, or both. The size of an organisation also matters and ARP can follow the example of TCFD in requiring companies with a certain level of employees or turnover to report mandatorily.

Other reporting regimes

Respondents agreed that a key principle of ARP reporting is that it should gather the necessary information whilst minimising reporting burden and duplication. Whilst respondents recognised some overlap with other reporting, such as that recommended by the Taskforce for Climate-related Financial Disclosures (TCFD), they believed ARP continues to be distinct from other regimes.

9. Is your organisation subject to existing or planned UK Sustainability Disclosure Requirements or any other relevant reporting regimes? How far do these go in fulfilling the objectives of ARP in your organisation?

There were 68 responses to this question, of which 38 (56%) said they were not subject to existing or planned UK Sustainability Disclosure Requirements or any other relevant reporting regimes.

The remaining 30 (44%) said they were or are expecting to be. Of these, no respondent said other reporting regimes entirely fulfil the objectives of ARP. Many noted that their participation in other reporting regimes is at an early stage so it is not yet clear how the sets of requirements overlap. TCFD was repeatedly cited as an example and respondents wanted alignment on the 2 frameworks as far as possible. Some respondents noted that they believe TCFD reporting is complementary to rather than a substitute for the ARP.

10. Are there any gaps which remain between the information provided under other reporting requirements and that of ARP? If yes, please provide details.

There were 66 responses to this question, of which 38 (58%) said they saw no gaps or were not in a position to identify any gaps. 28 (42%) said there was a gap or made comments indicating they felt there was one. Comments included:

• ARP reporting is dedicated to progress in adapting to climate change and is generally more detailed and qualitative than other reporting regimes
• ARP reporting remains predominantly about physical risks whereas TCFD concerns financial and strategic risks (and the associated plans to combat those)
• some reporting regimes request that adaptation and resilience are part of the assessment of climate risks
• some reporting regimes request disclosures on governance, strategy, risk management and indicators of progress
• though some regimes request it, monitoring and evaluation (using indicators) of adaptation plans is generally less well tracked
• interdependencies of risks and reporting of trade-offs with other (government) actions are general areas of weakness in most reporting regimes including ARP

To note, this question was primarily designed to elicit suggestions on gaps in other reporting regimes and there was no ‘don’t know’ option. Consequently the 58% figure should not be interpreted as a majority belief that other reporting regimes have no gaps.

11. Could your TCFD-aligned disclosures effectively replace ARP in round four or beyond? Please give any supporting reasons.

68 respondents answered this question. 62 (91%) said their TCFD-aligned disclosures could not effectively replace ARP in round 4 or beyond and 8 (9%) said they could. This figure should be interpreted with care as the ‘no’ answer includes organisations who do not participate in any TCFD-aligned disclosures, organisations who have only just started to do so or for another reason are not currently able to provide a confident view. There was no ‘undecided’ option, and those who were genuinely undecided are more likely to have selected ‘no’ than ‘yes’.

Analysis of follow-up answers indicates that many respondents do not have a strongly held view and would qualify their answers. Those who answered yes believe that TCFD disclosures ‘broadly cover’ ARP and those who answered no nevertheless acknowledge ARP can ‘conceivably be partially replaced’ by TCFD disclosures. A reasonable conclusion to draw, based on the large margin ‘no’ has over ‘yes’ is that TCFD disclosures do not fully replace ARP. Further comments included:

• TCFD and ARP could be complementary, mutually informative and both could be improved by considering the strengths of the other
• in particular, ARP should ensure that combination risks arising from the interrelationship of net zero transition and physical risks are captured
• TCFD’s guidance is much weaker for reporting on physical climate risks and adaptation than transition to net zero
• it would be helpful if any information that is reported in TCFD could be accepted in ARP reporting or vice versa to avoid duplication
• more organisations noted that their ARP reports contribute towards TCFD requirements rather than the other way around
• for some sectors, TCFD does not apply or the information provided to each of them is distinct
• 2 respondents suggested that ARP’s crossovers with TCFD be reviewed again after round 4 concludes

Sectoral approaches

Government has proposed to explore with those sectors that reported collectively in round 3 how they might best input to round 4. This may result in establishing a proportionate request for individual reporting, or by determining ways in which the information provided at sectoral level can be suitably enhanced and updated. This approach was widely supported by our consultation respondents.

1. Do you support a case-by-case approach to sectoral reporting, balancing the need for proportionality with the need for specific insights into the management of climate risks? Please give any supporting reasons.

There were 68 responses to this question. Of these, 42 (62%) supported a case-by-case approach to sectoral reporting, 7 (10%) were against a case-by-case approach to sectoral reporting and 19 (28%) were undecided. Reasons given included:

In support

• case-by-case approach may be the only form of reporting possible due to the specific risks faced by organisations in, and even within, different sectors

• it will make aligning with other reporting requirements easier for individual sectors
• it will reduce the burden on sectors that have fewer skills and less knowledge on reporting
• the appropriateness of umbrella bodies reporting on behalf of sector organisations varies between sector (and in some sectors these bodies are absent or do not have the full capability to coordinate joint responses)

Against

• case-by-case reporting may lead to some sectors providing more complete reports than others when we should be aiming for a consistent approach

• sector-based reports are helpful as summaries, but reporting by organisation rather than by sector is the only way to generate the amount of detail needed to assess action on adaptation
• the value gained by organisations working together with sector-wide groups to identify common risks and adaptation actions is not a substitute for individual organisation reporting which is the only way to ensure organisations take action

Further comments included:

• umbrella organisations reporting on behalf of organisations in the same sector means there is a group that drives progress and provides support, and will likely lead to the identification of interdependent risks – this would be a good thing irrespective of whether the case-by-case approach is taken
• a case-by-case approach is more appropriate for sectors that contain numerous smaller organisations but not for sectors that have established, larger organisations
• organisations that form a part of key sectors across the UK should face a greater requirement to report, regardless of size
• if a sectoral approach is taken, there needs to be clear criteria thresholds on the level of reporting
• a common framework for reporting can be developed for a specific area or sector, for example across National Parks
• in some cases regional level review and reporting may be even more suitable as it will reveal interdependent risks across sectors
• the appropriate format will need to be reviewed in light of sector changes

13. Who should be asked to report in the energy generation, telecommunications and digital sectors?

There were 31 responses to the question, excluding respondents who made no specific comment. Among the answers provided were:

• all major energy generators and distributors, and local generation above a certain output (one respondent suggested 10MW as the minimum size, another suggested a company that generates 5 or more percent of UK generation capacity)
• major telecommunications companies and those responsible for data centres
• all critical national infrastructure (CNI) operators, and potentially the underlying suppliers
• government bodies, including Ofcom and Ofgem
• the National Grid
• Distribution Network Operators (DNOs)
• trade and professional bodies in the sectors

Reporting by regulators

Respondents agreed that insights by regulators play an important role in building the picture of climate resilience across the regulated industries and reports should continue to be invited from them. Government proposed to invite all those regulators that were previously invited and to review those that were previously excluded from scope to determine whether this remains appropriate. Respondents made a number of suggestions of additional regulators that should be invited.

14. How can reporting by regulators best reflect their important oversight role?

There were 47 responses to the question, excluding respondents who made no specific comment. Among the answers provided were:

• regulators should ensure that they are encouraging their sector to properly assess risk and planning to adapt, and report on how they are driving and monitoring progress (as the CCC recommended) – this was the most common answer
• the consultation document appropriately frames the regulator in an ‘oversight and assurance’ role, and its reporting will be different to those who deliver or implement adaptation actions
• they should report on how they are updating regulatory approaches and how they integrate adaptation into an outcome-based framework that considers trade-offs with other objectives
• they should communicate the importance and benefits of reporting
• they should cover the areas where they have intervened and the impact this had, with evidence
• they should also provide their rationale for where they have not intervened
• they should be involved in the development of any sectoral reporting, and provide sector-wide summaries of adaptation preparedness
• they should assess interdependencies across sectors
• they should be given an oversight role on reporting compliance and take this into consideration when awarding future contracts

15. Which regulators should be invited to report in round four?

There were 37 responses to this question. Many regulators were named, including:

• Care Quality Commission
• Civil Aviation Authority
• Consumer Council for Water
• Drinking Water Inspectorate
• Environment Agency
• Financial Reporting Council
• Future System Operation
• Health and Safety Executive
• Local Authorities
• Office of Communications
• Office of Gas and Electricity Markets
• Office for Nuclear Regulation
• Office of Qualifications and Examinations Regulation
• Office of Rail and Road
• Office for Standards in Education, Children’s Services and Skills
• Pensions Regulator
• Rail Accident Investigation Branch
• Regulator of Social Housing
• Marine Management Organisation
• Natural England
• Natural Resources Wales
• NHS England
• Scottish Environment Protection Agency and
• Water Services Regulation Authority

Furthermore, 5 respondents suggested that all regulators should be invited to report in round 4. 2 respondents suggested that the existing list of regulators invited remains appropriate. One respondent queried who regulated CNI sectors and that they should be invited to report, and one wanted reporting from unspecified financial regulators.

Reporting on interdependencies and cascading risks

Respondents overwhelmingly agreed on the importance of reporting on and addressing failures that cascade across sectors. The proposal that in round 4, reporting organisations should explain their approach to identifying and managing interdependency risks on a voluntary basis was well received.

16. Would your organisation be able to report on interdependent and cascading risks? Please give any supporting reasons

There were 70 responses to this question, of which 30 (43%) said their organisation can report on interdependent and cascading risks, 19 (27%) selected no and 21 (30%) selected don’t know or provided text-based answers that can be most closely described as don’t know. These results should not be taken directly as a reflection of all organisations’ ability to report on interdependencies, as some respondents who selected no are not exposed to them. This applies, for example, to an academic institute researching adaptation.

Many respondents noted that they appreciate the significance of interdependent and cascading risks and will report on them, but nonetheless welcome further support to identify and address them. Further guidance on how these could be reported was also requested.

Respondents who answered yes tended to qualify their answers. Some noted that they are only able to identify a small range of interdependencies within their area of concern. Some found the ownership of interdependent risks, once identified, to be unclear. Interdependent risks within a sector were purportedly better understood than those across sectors. Many organisations mentioned ongoing pieces of work to better understand interdependencies, which may not be ready in time for ARP4.

Respondents who answered no and can reasonably be said to face interdependent and cascading risks noted a lack of resources for further analysis. Some suggested that, as a result, it would not be fair to add this additional requirement for the fourth round of reporting (or at least a detailed requirement). It was also suggested that reporting on interdependencies relies on cross-sector collaboration which is not always forthcoming even when actively pursued.

17. Would a requirement to report on the detail of interdependent risks help to drive progress in assessing and managing these? Please give any supporting reasons.

There were 69 responses to this question, of which 50 (72%) said yes, 4 (6%) selected no and 15 (22%) selected don’t know or provided text-based answers can be most closely described as don’t know.

Reasons and comments provided by those who selected yes and don’t know included:

• it will drive conversations in an area which many stakeholders do not currently understand
• it will highlight the importance of working across sectors
• it will provide more data and improve the quality of scenario planning
• there should be further requirements for collaboration between reporting bodies at a regional level to report on interdependencies and create actions to address them

Many respondents who answered yes qualified their answer with the challenges highlighted in the previous question and suggested that this should be voluntary for round 4 and further guidance is needed. Among other things, government could provide a map of interdependent risks, case studies, best practice principles and guidance on identifying, assessing and managing independent risks.

Some respondents suggested a 2-stage approach to the requirement for reporting on interdependent risks. Noting the limited timeline to ARP4, they suggested the focus should initially be for organisations to set out their approach on managing interdependencies, developing the internal pathways and links between assets. In round 5, there could be a full requirement to incorporate interdependent risks within risk assessments. Many other respondents agreed that a full requirement is reasonable for round 5 without also suggesting the intermediate step for round 4.

The respondents who selected no noted that interdependent risks do not apply to their organisation by nature, that they already consider interdependent risks in their existing plans, or have no resource to pursue this work in time for round 4. One respondent noted that this question has been discussed since ARP1 and there needs to be a centralised approach to identifying and understanding interdependencies and the levels of resilience across different sectors in relation to different climate challenges to inform planning.

18. How can government encourage cross-sector working and collaboration on interdependencies as part of the adaptation reporting process?

There were 64 responses to this question. The most common suggestions or otherwise relevant comments included:

• require reports on interdependent risks
• require coordination between regulators on resilience standards
• place a duty to cooperate on local infrastructure providers and local authorities
• promote understanding of key interdependent risks, for example by mapping the most important interdependencies for each sector
• refer to ongoing work such as the Climate Resilience Demonstrator Project
• establish the appropriate regulatory framework to set out responsibilities
• increase funding for risk management plans that do address interdependent risks
• increase funding for research into interdependencies, such as secondment programmes
• engage with local resilience forums
• create an enabling environment or communities of practice, deploying working groups and data sharing platforms to encourage join up of stakeholders across industries (both UK wide and within a certain region)

Guidance and templates

Government proposed to develop a template to facilitate reporting in the fourth round, balancing the need for reports to cover key areas whilst minimising reporting burden, given the shorter reporting window proposed. The usefulness of templates and guidance was widely noted by respondents. They also agreed organisations should not be mandated in round 4 to follow the structure of the template. Helpful suggestions on what the guidance should cover were provided.

19. Would reporting templates be helpful for your organisation? Please give any supporting reasons.

There were 71 responses to this question, of which 50 (70%) said reporting templates would be helpful, 6 (9%) said they would not be helpful and 15 (21%) were undecided. Reasons included:

Templates would be helpful

• they serve as a good practice guide for reporting by indicating the minimum reporting requirements
• they help frame internal discussions and make structuring the report easier, particularly for organisations reporting for the first time
• they enable consistency of reporting
• they enable comparison and information sharing among similar organisations

Templates would not be helpful

• some organisations have established their own template and it would be unhelpful if they needed to fit with the new template
• in general, organisations should not be required to report in the style or format of a template
• it is difficult to generate a template that takes account of sector-specific narratives
• a list of information required would be preferable

Other comments, including from the undecided included:

• a template for the water sector which has built-in flexibility was previously developed through consultation with a Defra-led working group
• that any template should be developed in consultation with organisations, and be designed with alignment with other reporting regimes in mind

20. Do you agree that following the template should be voluntary? Please give any supporting reasons.

There were 71 responses to this question, of which 38 (54%) agreed that reporting templates should be voluntary, 23 (32%) disagreed and 10 (14%) neither agree nor disagreed or provided text-based answers that can be most closely described as neither agree nor disagree. Reasons included:

Following the template should be voluntary

• a flexible approach is preferred to allow for the tailoring of the template
• organisations that are smaller or reporting for the first time in round 4 may be unable to provide all the information mandated by a template
• a voluntary template limits the burden on reporting organisations and limits the risk of duplication
• a mandatory template risks turning the reporting into a box ticking exercise

Following the template should be mandatory

• a voluntary approach will not be sufficient to drive the reporting standards up to the required levels
• a voluntary template would undermine its usefulness and impact
• consistency of reporting and its benefits outweighs concerns over flexibility
• organisations can freely provide information beyond the template but following one should be mandatory to elicit information that is required

Other comments, including from respondents who neither agree nor disagree included:

• templates should be restricted to information that would be useful and useable for government, CCC and academic researchers
• some parts of the template should be mandatory and others parts voluntary depending on the organisation
• templates should align with other existing reporting frameworks where possible
• templates should cover information about an organisation’s corporate governance
• templates are just as likely to be ignored if their use is mandatory as if their use is voluntary
• templates, irrespective of whether it is voluntary or mandatory, should be flexible enough to accommodate organisations submitting joint responses
• the use of a mandatory template should be reviewed ahead of ARP5
• if adaptation reporting becomes mandatory then the use of templates should also be mandated, and vice versa

21. What supporting guidance would be useful to minimise reporting burdens and ensure that reports are generating useful insights?

There were 63 responses to this question. The most commonly raised points included:

• a template and thorough guidance, potentially in the form of a checklist

• explanation of what information is minimally required and why

• explanation of how information collected will be used and by whom
• examples of best practices for difference sectors
• standardised methodology on conducting risk assessments and digital tools
• standardised approach to risk prioritisation
• providing greater information on monitoring and evaluation of actions
• sectoral and regional risk summaries that will help organisations prioritise risks
• simplified and standardised climate scenarios
• that the guidance be sensitive to the different level of climate risks, allowing risks that are identified but deemed to be of low consequences to be partially reported
• a tool for assessing interdependencies and cascading risks
• allow for greater alignment with other reporting regimes, such as accepting material generated for CDP or TCFD

Evidence and risk assessment

Given the compressed timeline we proposed and the need to minimise reporting burden, we proposed that organisations who submitted reports in the third round should not have to complete another detailed risk assessment in round 4. This was supported by most respondents, who also believed that government should pursue a standardised approach to risk assessment and provide specific climate scenarios to reporting organisations.

22. Should government pursue a standardised approach to risk assessment, including by mandating the use of specific climate scenarios? How would this affect your ability to respond, and to assess risk according to your organisation’s specific circumstances?

There were 70 responses to this question, of which 49 (69%) said they supported government pursuing a standardised approach to risk assessment, including by mandating the use of specific climate scenarios or gave text-based responses that can be most closely described as supportive of the statement. 21 (31%) of responses said they did not support a standardised approach to risk assessment or gave text-based responses that can be most closely described as unsupportive of this statement.

To note, the above figures do not account for some respondents who were supportive of a standardised approach to risk assessment but not the mandatory use of specific climate scenarios, or vice versa. Furthermore, irrespective of how they selected their final answer, many respondents qualified their answers with arguments for the opposing views. Some advocated for a blended approach tailored to and co-designed with sectors. It was also repeatedly noted that mandatory use of specific climate scenarios will be better suited for round 5 rather than round 4 of reporting. Reasons given in support of the 2 positions included:

Supportive of a standardised approach to risk assessment and mandatory use of specific climate scenarios

• much more consistent assessment will be provided, ensuring a common baseline of understanding, which will allow better intra- and inter-sectoral comparison and analysis
• a standardised approach reduces some administrative burden and makes it easier to report, particularly for organisations that are reporting for the first time
• it makes collaborating with partner organisations easier
• all organisations should work to the most realistic climate scenario (although there was disagreement as to what this should be)
• organisations are free to consider other climate scenarios in addition to those mandated

Unsupportive of a standardised approach to risk assessment and mandatory use of specific climate scenarios

• standardised approach unlikely to benefit the organisation’s internal, general risk management systems
• specific climate scenarios cannot accommodate every organisation spread across the UK, given regional differences to the effects of changing climates
• a plausible alternative to a fully standardised approach is for sectoral or regional organisations to develop a common reporting framework
• some organisations are already required to use specific approaches, such as the Representative Concentration Pathways for nuclear energy generation
• standardised approach will increase the reporting burden for organisations that are used to working to different risk assessment approaches
• organisations are at different stages of their climate risk assessment and mandating an approach may risk many null responses
• transition to standardisation would take time and should not be mandated by ARP4, particularly given the shortened timeline for reporting
• different climate scenarios should be used, proportionate to the inherent risk the organisation or sector faces
• the selection of climate scenarios (and risk assessment approach) should be sector-specific and co-developed rather than mandated by government

23. Do you agree that organisations that reported in the third round should not be required to submit full risk assessments in round four, and that reports should instead focus on updates to actions taken in response to risks? Please give any supporting reasons.

There were 69 responses to this question, of which 46 (67%) agreed that organisations that reported in the third round should not be required to submit full risk assessments in round 4, and that reports should instead focus on updates to actions taken in response to the risks. 16 (23%) respondents selected no, but this figure included at least 5 respondents who noted that this was not a question for them. There was no option for undecided or not applicable. Irrespective of how the respondents answered, many noted the importance of updating the risk assessment approach if there is a change. Among the further reasons provided were:

Organisations that reported in the third round should not be required to submit full risk assessments in round 4

• reducing of reporting burden which is appropriate given shortened timeline
• organisations have the voluntary option to update on their previous risk assessments to reflect any advances in the evidence base
• some organisations have kept the same risk assessment approach since ARP1 which is appropriate as they assess risks over relatively long time frames compared to others
• no pieces of work that will significantly affect risk assessment approaches are scheduled to be released in an appropriate timescale for inclusion in the proposed round 4 reporting timeline (one respondent noted that the updated Environment Agency flood maps are scheduled for release in 2024 but timings would not allow for a meaningful analysis)

Organisations that reported in the third round should be required to submit full risk assessments in round 4

• reporting on risk assessment should be in full and on a regular basis, even if it mostly builds on previous reporting as they help the assessor understand the plans and policies proposed
• if any material aspects of an organisation’s operations have changed since round 3 then it is essential for organisations to update the risk assessment
• equally, it would be easy for organisations to include an existing risk assessment approach if they believe there has been no change
• government should assess previously submitted risk assessment approaches and, where necessary, ask individual organisations for updates
• previous risk assessments have been voluntary, not standardised and inadequate, and should be improved for this round
• if this is not a requirement for round 4, organisations must be required to produce updated risk assessments for round 5

Scope

Government has broadly followed the CCC’s recommendations on the scope of reporting and has suggested an expansion in 4 key areas: health and social care; canals and reservoirs; landowners; and agriculture and food supply chains. A majority of respondents agreed with this approach and a small number of prospective reporting organisations have indicated willingness to participate in a pilot.

24. Have we selected the right areas to prioritise for targeted scope expansion in the fourth round of reporting?

There were 67 responses to this question, of which 42 (63%) agreed, 4 (6%) disagreed or provided text-based responses that can be most closely described as disagree, and 21 (31%) don’t know. Irrespective of how a respondent answered, they were keen to suggest further areas for inclusion, such as:

• construction and house building
• all organisations identified as CNI
• defence
• Internal Drainage Boards

Respondents came from a wide range of sectors and they were generous with providing further comments, including:

• it is sensible to follow the CCC’s recommendation on priority target areas for expansion, particularly local authorities and health and social care
• there needs to be greater specification in the local authorities, such as lead local flood authorities or local planning authorities
• the breadth of reporting in sectors already in scope should expand, for example in energy and ICT
• focus on filling the gaps in existing sectors must not be lost
• in expanding the scope to include landowners, smaller landowners should be out of scope to ensure proportionality and organisations invited to report must be of a public nature
• further review should take place ahead of round 5
• government should encourage all organisations, irrespective of ARP4 scope, to adapt to climate change

25. How would a reporting pilot be received in your sector?

There were only 9 responses to this question. Within this, 2 said a reporting pilot would be very well received in their sector, 3 said it would be well received, and 4 said it would be poorly received or provided text-based responses indicating that it would be poorly received. A limited number of points were raised, including:

• pilots would be useful if participants can influence the shape of future reporting and the work produced can be transferred to a wider rollout at a later stage
• the shortened timescale for ARP4 is not adequate for a pilot reporting scheme
• some organisations already report through other existing regimes and a pilot will add extra burden and is likely to have low uptake
• mandatory approach will not be well received
• some organisations would prefer working with Defra outside of the ARP to consider the risks of climate change and adaptive action needed

26. Which organisations should be invited to report and how should we determine proportionality in these sectors?

There were 9 responses to this question and comments included:

• organisations covered in existing priority sectors should continue to be invited
• any additional organisations with responsibility for managing major infrastructure, national assets or critical supply chains should be invited
• for landowners, this could include the National Trust, RSPB, Wildlife Trusts, Woodland Trust, and possibly Church of England, Crown Estate and Duchy of Cornwall
• for canals and reservoirs, this could include internal drainage boards
• for health and social care, NHS England and the UK Health Security Agency should report on behalf of the health system, including Integrated Care Systems and Trusts

On the question of how proportionality should be determined, respondents said the following criteria mattered:

• size of organisation
• size of budget
• level of vulnerability or risk from climate change
• scale of adaptation investment required
• ambition of plans and policies so far
• progress so far

It was noted that many of the measurements above are useful as proxies for capacity to enact adaptation and impact of the actions undertaken. One respondent also noted that if smaller organisations are invited to report this should be voluntary and simplified.

27. Would your organisation be willing to take part in a pilot in round 4 of the ARP?

There were 9 responses to this question. 4 respondents said they were willing to take part in a pilot, one said they were unwilling, and 4 said they were undecided.

Local government

Government proposed to work with Local Authorities to consider how they can be supported to report on and address risks posed by climate change. There was support among respondents to pilot a form of adaptation reporting with a small group of local authorities of different types.

28. Do you agree that Local Authority reporting should be piloted with a small group of authorities in round four of ARP, to test the costs and benefits? What form should this take? Would your organisation be willing to take part?

There were 21 responses to this question. 20 agreed that Local Authority reporting should be piloted with a small group of authorities, to test the costs and benefits. One respondent, a Local Authority, disagreed because they believe Local Authorities should be reporting on climate adaptation as a matter of course. Further comments included:

• the pilot should ensure a geographical spread across the country and a mixture of urban and rural representation

• it should ensure a representative selection of unitary and 2-tier authorities, with city, district, county, parish and town councils all represented
• it should also ensure representation from Local Authorities that are at different levels of ‘maturity’ when it comes to reporting on and adapting to climate change
• the pilot would be useful for councils to understand the time and resourcing requirement for reporting, and for government to recognise the varying ability of Local Authorities to report
• there are ongoing regional commitments and adaptation programmes that could be utilised by the pilot
• 62 Local Authorities already report through Carbon Disclosure Project and may be good candidates for the pilot

All Local Authority respondents to this question said they were either willing to participate in, or undecided on participating in the pilot. A few other respondents who were not Local Authorities expressed willingness to support the process.

29. What advice, guidance and incentives do Local Authorities need to help develop their climate risk management practices?

There were 21 responses to this question. Among the suggestions and comments were:

• clear information on regional climate risks
• clear information on the benefits and costs of pursuing adaptive actions
• resources, including financial or investment incentives
• guidance and best practice on developing risk management programmes
• training on adaptation pathways methodology
• access to robust and useful data sets

• greater engagement from and with industry, regulators and the CCC

• central government coordination and clear division of labour on areas where there are existing management practices versus areas where Local Authorities have to create their own adaptive capacity anew
• an enabling environment created by government to encourage knowledge sharing and the development of cross-sectoral, regional approaches
• a mandatory reporting requirement
• a legal duty that ties planning regulations to climate adaptation

It was also noted that there are existing, relevant materials from Defra, Local Partnerships, the Local Adaptation Advisory Panel and the Association of Directors of Environment, Economy, Planning and Transport. This supports a wide range of commitments and activities which some Local Authorities are already undertaking to adapt to climate change.

Devolved and reserved matters

Government has noted that a voluntary approach to reporting in round 4, whereby the government would not be issuing directions to reporting organisations, would not conflict with the devolved administrations’ corresponding powers over reserved, non-devolved or excepted matters. There were no challenges to this approach.

30. Do you agree with the ARP approach to reporting by organisations with activities in the territorial extent of one or more of the devolved administrations? Please elaborate.

There were 7 responses to this question. 6 agreed with the approach to reporting by organisations with activities in the territorial extent of one or more of the devolved administrations or provided text-based responses that can most closely be described as such. Further comments for this question noted that the same approach worked well in the previous round of reporting and aligns with organisations’ existing practices.

One respondent answered no but did so because there was no option for undecided. They sought clarification on reporting requirements for Internal Drainage Boards.

Costs and benefits of reporting

31. What is the estimated total cost (time and resource) of reporting for your organisation?

There were 37 responses to this question with distribution of costs detailed in table 1.

Option	Number of responses	Percent (to 1 decimal place)
Less than £20,000	5	6.7%
£20,001 to £30,000	4	5.3%
£30,001 to £40,000	3	4%
£40,001 to £50,000	4	5.3%
£50,001 to £60,000	4	5.3%
£60,000 to £70,000	1	1.3%
More than £70,000	13	17.3%
Text-based answer	3	4%
Not answered	39	51.3%
Total	76	100%

The 3 text-based answers were as follows:

• one estimated the cost to be between £50,000 and £70,000
• one described the cost of reporting as significantly more than the government estimates indicate without providing a figure
• one estimated that the cost was one full-time equivalent employee during the course of the reporting process, again without a figure

32. If you have reported in the past, in what ways has the exercise been useful to your organisation?

There were 41 responses to this question. Respondents were free to select multiple options of how previous reporting has benefited their organisations and the table 2 shows the frequency at which each suggested option was selected.

Option	Number of responses
Making climate risk management a leadership priority	27
Integrating climate risk management into governance and operations	30
Encouraging collaboration	22
Sharing best practice	24
Other	14

Many respondents, including those who selected ‘other’, provided other benefits of reporting or comments which included:

• many organisations found their first reporting experience to be most beneficial
• reporting helped generate an overview of an organisation’s climate risks and how that will affect their operations
• reporting provided an opportunity to raise awareness of adaptation, collaborate on policies and celebrate success with customers, stakeholders and regulators
• reporting illuminated how some organisations are creating risk assessments and plans with no funding besides staff time
• linked to the above, reporting supported the investment case for pursuing actions in climate adaptation
• reporting encouraged some organisations to build their own adaptive capacity
• the benefit of reporting decreases over time as adaptation becomes embedded
• reporting helped organisations to consider interdependent risks
• ARP reporting is a useful exercise to ensure the organisation is prepared to meet the reporting requirements for TCFD if they are also required to report there

However, not every organisation found adaptation reporting to be useful:

• some organisations did not find reporting to be useful to them, except in highlighting the need to adapt
• some respondents said that while reporting did raise the profile of adaptation, it was still not considered a leadership priority
• climate change resilience has been part of some organisations’ business planning since before the first round of ARP and even the 2008 Climate Change Act

Further review of Adaptation Reporting

33. What additional questions would you pose for future reviews of climate adaptation reporting?

There were 34 responses to this question. Among the suggestions were:

• how do we calculate and trade-off the estimated costs of not adapting
• how do we account for the costs on responding to climate-driven incidents

• how are regulators communicating the benefits of and driving reporting

• how is progress monitored and evaluated
• how is maladaptation identified and addressed
• how reporting organisations can contribute to UK-wide adaptation through the use of their infrastructure assets
• what are the priority interdependent risks, who needs to be involved and who will coordinate action across the sector to address them

• what investment is needed, both private and public

• what regulatory instruments would facilitate adaptive actions and
• what approach are organisations taking on decommissioning assets

Referring to the role of Defra and government, respondents also noted that it would be helpful to know:

• if and how has government fed back on previous rounds of reporting and followed up on the lack of action
• when additional evidence, such as the next UK Climate Projections data, will be released and how they should feed into ARP reporting
• how government will reduce the reporting burden for organisations and ensure there is no duplication
• if the government has considered whether reporting should require adaptation pathways
• whether the government has considered a legal duty that ties planning to net zero goals and adaptation
• if the government will commence work on ARP5 in parallel with developing the fourth-round guidance

Government response to the consultation

Defra is grateful for all the responses to the consultation. In addition, we are grateful to all the reporting organisations which took part in the informal discussions over autumn 2022 which helped build this set of proposals.

These responses give us broad support to pursue the proposals on which we consulted, which were centred around the realignment of reporting with the rest of the statutory framework for climate change adaptation. Government will now finalise its policy-setting strategy for the fourth cycle of the ARP and incorporate it into the NAP3. This will demonstrate the contribution this reporting process will make to the overall programme of work to address the risks in the UK Climate Change Risk Assessment. NAP3 will be laid in Parliament later this year.

Annex A: List of respondents

• Association of Drainage Authorities
• Affinity Water
• Airport Operators Association
• Associated British Ports
• Blaby District Council
• British Ports Association
• Cadent Gas Ltd
• Canal and River Trust
• Chartered Institution of Water and Environmental Management
• Civil Aviation Authority
• Consumer Council for Water
• Darlington Borough Council
• EDF Renewables UK
• Electricity North West
• Energy Networks Association
• Energy UK
• Environment Agency
• Financial Conduct Authority
• Grantham Research Institute
• Institute of Environmental Management and Assessment
• Institution of Civil Engineers
• Kent County Council
• Kingston upon Hull, City of Council
• Kirklees Council
• Leeds City Council’s Climate Emergency Advisory Committee
• Leicestershire County Council
• Marine Management Organisation
• Maritime and Coastguard Agency
• Ministry of Justice
• Mott MacDonald
• National Farmers’ Union
• National Grid Electricity Transmission and Distribution
• Natural England
• Network Rail
• NHS England
• North York Moor National Park Authority
• Northern Lighthouse Board
• Northern Powergrid
• Northumberland National Park Authority
• Peel Ports
• Port of London Authority
• Portsmouth Water Ltd
• Royal Botanic Gardens, Kew
• Royal Society of Wildlife Trusts
• Security Industry Authority
• Severn Trent
• SGN
• South Downs National Park Authority
• South Gloucestershire Council
• South West Water Ltd
• SSEN Distribution
• Staffordshire Sustainability Board
• Thames Water
• The Pensions Regulator
• The UK Major Ports Group
• Transport for London
• Trinity House
• UK Power Networks
• UK Space Agency
• United Utilities
• Wales and West Utilities Ltd
• Warwick District Council
• Water Services Regulation Authority
• Welsh Government
• West Midlands Combined Authority
• West of England Combined Authority
• Yorkshire Water