NAP3: Where is the Urgency?

Proposals to Mitigate Climate Risks Lacklustre: A Review of the Third National Adaptation Programme (NAP3)

“This programme represents a step change in our approach to managing the risks of climate change, moving us from planning to action. It represents the beginning of a 5-year programme of work across government to build our resilience to climate change.”

These were the words of the Environment Secretary, Therese Coffey, in a report setting out the government’s objectives on climate change adaptation in the UK. With its action-oriented rhetoric, you might be forgiven then for thinking that the recommendations within in the latest National Adaptation Programme (NAP), a government climate resilience report published every 5 years, would reflect the emergency of global heating and its impacts on the country’s most vulnerable. Not so, say experts.

It was hoped the report, initially touted for release earlier on Tuesday but leaked to The Guardian over the weekend, would simply have more teeth; with the immediacy of the climate crisis apparent to most across the UK, a more in-depth programme of policies that fully support the UK’s leadership on climate would have been welcome.

The immediacy of the climate crisis and its potentially devastating impacts were highlighted earlier this year in a report published by the Climate Change Committee (CCC), articulating how the UK is “strikingly unprepared” for the impacts of climate change and that this year’s NAP is a “make-or-break moment” to improve the country’s preparedness. It was therefore disappointing to many experts to see a government plan that appears not to respond to what most perceive as an emergency.

The CCC report stated that the next National Adaptation Plan (NAP3) “must be much more ambitious” than those that had come before it, and pivot government priorities to focus on the delivery of effective adaptation.

A backlash from all sides

Within just a few hours after the NAP report was leaked, it was already facing a torrent of criticism from all sides, be that climate experts, environmental campaigners, or even parliamentarians. For instance, the same day that the report was published, Caroline Lucas, the Green Party parliamentary candidate, tweeted that the NAP is “desperately lacking in urgency and ambition” and how the government needs urgent action “to protect homes & restore nature”.

The comments from Lucas thus reflect the primary criticism being levelled against the report: it is simply disappointing, given the immediacy of the climate crisis and how nations need to be showing firm commitments to combatting the worst of its impacts.

It would seem such criticisms are well founded, particularly in light of the events of last year. According to recent estimates, the heatwaves that struck the UK last year, during which the mercury recorded temperatures exceeding 40 degrees for the first time, resulted in over 2,800 excess deaths. This was primarily in the 65-plus age group and included a spike in deaths as temperatures reached their peak.

These figures, compiled by the Office for National Statistics (ONS), demonstrated that the number of people who died across all age groups in England and Wales was up 6.2% compared with the 5-year average. This was alongside NHS data showing a marked uptick in admissions, 111 calls, and ambulance callouts for heat-related conditions, such as heatstroke and sunburn.

Alongside a series of criticisms from environmental experts, Isabel Oliver, the chief scientific officer of the UK Health Security Agency (UKHSA), was quick to share her thoughts.

“Higher excess deaths occurred during the hottest days this year and a warming climate means we must adapt to living safely with hotter summers in the future,” she said following publication of the ONS data. Such a statement from a UKHSA chief, one of the contributing organisations of NAP3, would thus likely reflect the government’s actions in combatting the worst effects of climate change, but this doesn’t appear the case.

STUK’s position

Amongst criticisms of a lack of urgency and scale, the widespread recycling of older policies, and a general inability to protect livelihoods, one area we at STUK take issue with greatly is its lack of focus on housing infrastructure and protection against heatwaves.

Looking into chapter 4 of the report, “Health, communities, and the built environment”, we at least see recognition from the government that the climate poses risks to health and wellbeing across the country, particularly resulting from high temperatures, changes in air quality, and flooding. Here, the report lists a handful of recommendations that would enhance the thermal efficiency of buildings and address overheating risks.

Take also, for example, the Part O Building Regulations introduced in 2022; the Department for Levelling Up, Housing and Communities (DLUHC) implemented measures mandating all new residential buildings limit excess heat and solar gain in an effort to futureproof new developments against increased temperatures.

The issue here however, reflecting the views of many critics, is that the proposals simply do not go far enough in addressing the scale of the challenges. Namely, there has consistently been a lack of consideration towards existing buildings, most of which have not been adapted to be protected against future heatwaves. The NAP3 unfortunately does not address this shortfall, particularly considering how no significant progress has been made on retrofitting since the heatwaves of last year. Although the government has tasked another department to develop measures to retrofit existing buildings to reduce overheating and mitigate climate risk, no concrete proposals are in the offing.

And whilst the government may talk about policies to help alleviate the pressures of heatwaves and the climate crisis, what we consistently see in their approach to communication is an absence of its impacts on the general public. We may understand now the number of excess deaths from recent heatwaves and ideate solutions to this problem, but time and again there is a lack of focus on those that this crisis impacts; those who suffer the worst effects of heatwaves are real people with real lives. For a moment, we should put the statistics to one side and sympathise at a human level.

Here at STUK, we implore the government to go further in their climate commitment in order to achieve our ideal of zero deaths from overheating. Based on their recent report and the widespread criticism to it, we urge the government to consider the following recommendations in order to achieve that goal:

• Work to find immediate support for vulnerability groups during heatwaves.

• Swiftly implement a nationwide retrofitting programme, aiming to sustainably adapt all residential buildings via passive cooling measures, with a goal of eliminating all heat-related deaths by 2035, when the globe is likely to have crossed the 1.5°C threshold of warming.

• Mandate temperature limits at which it is no longer viable to teach, work, or occupy certain buildings such as schools, workplaces, and public spaces across the UK.

• Commit to the widespread investigation of how heatwaves and climate change present risks to all groups across society, including in schools, care homes, social housing, hospitals, and the homeless.

We firmly believe that it is only through defined, hard-hitting policies that recognise the immediacy of the climate crisis that we will be able to build a country that is capable of staving off the worst consequences of climate change.

Written by Oliver Longstaff