Government has recently committed to reviewing its approach to national resilience. 1 As part of this, government should explore the above gaps and consider if there are others when publishing its first round of resilience standards for economic infrastructure.
Publishing resilience standards in each sector will not only support future resilience planning. It will also enable each sector to understand levels of resilience in other sectors to help manage interdependency risks. Government department should set standards for each sector, with the method and timetable depending on the different regulatory structures in each. Cabinet Office can then play a coordinating role in ensuring that cross-sector interdependency risks, such as the reliance of digital and telecoms, transport, and water networks on power, are managed effectively.
Resilient infrastructure can continue to provide the services business and communities rely on despite short term shocks. Resilience often requires additional investment which may cost money in the short term but avoid costly impacts during shocks.
The Commission’s analysis has previously demonstrated that the cost of proactively building additional water supply capacity would be significantly less expensive than emergency measures in the event of a severe drought. 2 However, many service shocks are infrequent, and while the cost of intervention is immediately evident, future benefits are uncertain. Both the public and private sectors are likely to underinvest in infrastructure resilience unless the government sets expectations across regulatory and spending cycles, and through standards which have public backing. This will limit the impact of shocks and support recovery, so disruption from events does not lead to major harm.
Setting out clear resilience standards will also help businesses and consumers to plan. If clear standards are in place, then consumers and businesses can understand the degree to which they might need to plan for their own resilience, such as through storing water on the premises or using alternate routes to make journeys. It will also enable government to advise on what levels of individual resilience might be appropriate for households and businesses.
In its second National Infrastructure Assessment the Commission recommended that government should publish resilience standards for the digital and telecoms, energy, transport, and water sectors by the end of 2025 (see box below). This report sets out how government can progress this recommendation.
By 2025, government should
Standards in infrastructure operate at different levels, from the outcome based resilience standards the Commission has recommended to detailed technical standards for specific assets. There are four broad categories of standards:
Customer outcome standards
These standards are based on the quality of service received by customers. Regulatory performance incentives on levels of service can be regarded as a type of standard. For example, water supply interruptions above three hours are both measurable and are regarded as having a material impact on customers, and so the total duration of any interruptions above three hours is subject to regulatory incentives and penalties. 3
System performance standards
These standards dictate how the system is expected to perform in certain circumstances, but only indirectly link to customer experience. For example, in the energy sector there are codes specifying the level of resilience required in the electricity transmission system. In the water sector, the Drinking Water Inspectorate’s Compliance Risk Index score measures the risk arising from specified treated water compliance failures. 4
Technical asset standards
System assets are also required to meet specific technical standards which dictate their tolerance to different events, including changes in the surrounding climate. For example, rails in the UK are designed to a stress free temperature of 27°C. If they experience temperature significantly above this, rail buckling can lead to service disruption. 5 These standards also cover how assets are used – such as thermal ratings for overhead lines
Recovery standards
These standards set out what is expected in the event of a service failure, both in terms of restoration of service and in terms of support services to customers while the service is down. Consumers are entitled to compensation if their water supply is not restored within a 12 hour period, implying a standard for water companies to restore supply within that time. While supplies are down, customers are entitled to at least ten litres of water per person per day within 24 hours. By contrast, for digital services, customers registered with companies signed up to Ofcom’s automatic compensation scheme are entitled to compensation if a fault is not resolved within two full working days. 6
In this report the standards the Commission is referring to are customer outcome standards, underlying system performance standards for proactively designing resilient networks, and recovery standards. Technical asset standards are out of scope, though the Commission recognises that they will play a key role in ensuring asset systems achieve service level resilience standards.
Future resilience is critically important because as the third Climate Change Risk Assessment highlighted, a changing climate will lead to new threats to infrastructure services. 7 Extreme heat could create problems for rail networks, drought related subsidence could damage underground water pipes and rail embankments, and increased flood risk could threaten most services. In its second National Infrastructure Assessment the Commission found that no infrastructure operators had yet publicly set out the costs of making the delivery of their services resilient to climate change. Infrastructure operators need to understand the standard of resilience they are expected to provide in order to design and cost future resilience.
The resilience of the UK’s infrastructure services is also evolving due to technological change and because of the need to transition to net zero carbon emissions by 2050. Increasingly, infrastructure services are dependent on telecoms infrastructure for control and monitoring and so the consequences of these systems failing are becoming more severe. Equally, the transition to net zero is driving an increasing reliance on the electricity system for heating homes and powering transport, also adding to the consequences of the system’s failure.
Finally, resilience will be less costly if it is designed into systems which are already investing for other reasons. For several decades, sectors such as energy transmission and distribution, transport and water have operated as mature systems maintaining a steady state and managing incremental growth. But the second National Infrastructure Assessment highlighted that to deliver net zero, enable growth across regions, and to support resilience to a changing climate, this status quo is not sustainable. The UK will need to start building infrastructure networks at scale to ensure we can transmit enough electricity to power electric cars and heat pumps, have enough water to support a growing number of homes and improve mobility in congested cities.
To support the government in developing resilience standards, the Commission has conducted a literature review to understand current potential gaps in standards that government may wish to fill. It has also engaged stakeholders in a series of sector specific roundtables in the digital and telecoms, energy, transport and water sectors to understand how government can take this recommendation forward. The report sets out some indicative resilience gaps the Commission has identified, core principles for setting resilience standards and next steps for government.
Resilience standards can be challenging to set. Firstly, a patchwork of resilience standards already exists across the digital and telecoms, energy, transport and water sectors. The Commission has reviewed these standards set out in Annex 1. Government will need to consider these gaps and identify priority areas for a first round of standard setting and determine whether existing standards need to be updated. The Commission has recommended that standards should be reviewed every five years to address changes in the threat environment, in the technology available to address them, and in public attitudes to disruption. This means that there is potential for systems to become more resilient over time as new standards are added in each review period or as existing standards are strengthened. Five year reviews are also an opportunity to consider which are the most high priority standards within the system based on the government’s risk appetite – how it decides to approach the trade-off between additional resilience and affordability.
A second challenge to standard setting is identifying a ‘first mover’. Government is reluctant to set a resilience standard without understanding the costs of that standard. But infrastructure operators argue that they cannot cost resilience until they understand what the target level of resilience is. Setting standards is therefore necessarily iterative, as providers must draw up a menu of costed options which government should ultimately choose from. A blueprint for this is the Commission’s identification of a drought resilience standard. The Commission identified the costs and benefits of several drought resilience options. It then recommended that water companies should be asked to plan for a drought with a 0.2 per cent annual probability because proactive resilience – managing leakage and demand and building new supply infrastructure – would cost roughly half as much as reactive measures. Since then, the water industry has assessed options and proposed costed programmes for achieving this standard.
There is a trade-off for government in setting service standards. Setting a high level customer outcome standard gives consumers an understanding of the level of service they should expect, while giving infrastructure operators the flexibility to deliver that standard in the most efficient way possible. However, this approach makes it hard to measure whether desired levels of resilience have been achieved because for long life infrastructure assets system performance is a lagging indicator. For example, short term performance can be maintained by reducing redundancy in a system, such as reducing the number of water mains supplying an area from two to one. This would not lead to an immediate change in outcomes for consumers, but overall resilience would be reduced. To resolve this, regulators can require network operators to maintain specified levels of redundancy in their systems, or specify stress tests to explore the underlying resilience of systems. However, increasing output requirements, in terms of specific infrastructure interventions, can remove the flexibility for system operators to innovate when delivering system outcomes. The question for government is how far innovation and efficiency should be valued over standardised and more predictable system resilience.
Finally, there is also a potential trade-off between stringent requirements to maintain services at all costs and the need to restore systems as quickly as possible if service is lost. For example, if a very high level of resilience is too expensive, it may be preferable to focus efforts on restoring service swiftly in the event of an outage and to rely on emergency measures in the meantime. For example, having teams available to clear routes of debris left by flood waters or landslips can ensure the rapid recovery of transport networks. As the Commission’s resilience framework (Figure 1) highlights, operators should have recovery strategies in place as well as maintaining required levels of service resilience, as 100 per cent resilience is rarely if ever achievable or cost effective. Additionally, if systems propose to rely on emergency measures, such as the provision of bottled water in the event of water system outages, these must be tested with the public to ensure they are tolerable and preferable to proactive resilience.
National Infrastructure Commission Resilience Framework
Stakeholders across all sectors reported common principles that departments should consider when setting resilience standards:
The Commission undertook a literature review and four sector specific roundtables to identify possible gaps in resilience standards in the digital and telecoms, energy, transport and water sectors. The Commission found a series of sector specific gaps which individual government departments should consider addressing in a first round of standard setting. The roundtables also highlighted a more general concern about interdependency risks.
In the second National Infrastructure Assessment , the Commission recommended that a system should be put in place for cross sector stress testing which addresses interdependencies and the risk of cascade failures. Stress testing, through simulating how systems might react to shocks and stresses, can help infrastructure operators identify and address vulnerabilities in advance of an event. It can also help infrastructure operators test decision making processes, preparing operators for disruptions other than those in the scenarios set out in the stress tests. To ensure the stress tests address vulnerabilities, regulators should set out scenarios and scope for stress tests – providing guidance for developing bespoke tests where necessary – and oversee them, scrutinising outcomes and requiring operators to develop and implement plans to remedy any vulnerabilities identified. To ensure these stress tests are carried out as effectively as possible, in its 2020 report the Commission called for the UK Regulators Network to promote sharing of best practice in stress testing across relevant regulators, including learning lessons from the financial sector and other stress testing already in operation. 10
While each sector needs to take action to manage its own risks, in some cases a systems approach may be more efficient. The Climate Resilience Demonstrator has been exploring how information sharing about risks facing all sectors in a geographical area could lead to more efficient common solutions. 11 For example, a communally funded flood defence covering digital and telecoms services, energy and water networks, may be more affordable than individual defences for all three kinds of assets. Greater data sharing must be enabled and encouraged to allow these kinds of efficient investments to emerge and they must be fundable by each sector’s regulatory system. Regulators should work together to overcome potential challenges caused by differing timelines for regulatory reviews and budget setting in each sector. Greater sharing of data will also enable more strategic decisions about which services might need to be restored first in the event of a service outage in one sector – such as a power cut – to limit the impact of cascade failures. This action is in addition to addressing sector specific challenges set out below.
Public telecoms networks – including fixed broadband and landline and mobile services – are subject to a different model of regulation than the private and public regulated asset bases in the energy, transport and water sectors. Ofcom provides guidance to service providers on the approach that it would normally expect them to take to ensure service security and resilience. Service providers can adopt different solutions but are required to justify this approach in the event of a service outage. This guidance sets out relatively detailed expectations on the level of redundancy required in systems and on how to account for flood risk to core sites.
No standards are set for service levels. Instead Ofcom provides consumers with information about provider service levels such as the number of faults per 1,000 customers per month and the median average download speed by connection type. Additionally, most providers are signed up to the automatic compensation scheme in the event of long duration service outages, which should incentivise companies to recover services rapidly. Government should consider whether it wishes to set target customer outcome standards in addition to Ofcom’s existing resilience guidance for networks.
However, Ofcom should review its information for consumers on service levels provided by networks to ensure its information on resilience is adequate and accessible. For example, Ofcom has a requirement for customers dependent on a landline to be able to contact 999 for at least an hour in the event of a power cut. 12 But customers who are dependent on mobile services may find themselves unable to contact 999 if their mobile service goes down and they are using a mobile provider that has not enabled voice over WiFi calling as a back up. Consumers may struggle to understand these differences in service provision when choosing a provider unless information is accessible.
Other infrastructure networks – energy, transport and water – use private telecoms networks for some services. Private telecoms networks are not subject to Ofcom’s guidance, and this could create resilience challenges where these networks serve critical national infrastructure. Some stakeholders have suggested that these networks may not need to meet the same resilience requirements as public networks because private customers are already very resilience focused and so the market will drive resilience, and that stringent requirements might stifle innovation. However, there are several reasons why private telecoms networks may need to be subject to clear standards where they serve critical national infrastructure:
There are a number of options for ensuring the resilience of private telecoms networks, set out below:
In this report the Commission has not been able to assess the scale of current and future threats to resilient services caused by a reliance on private telecoms networks, or the relative benefits of the above options for addressing them. Government should consider these options as it considers future resilience standards.
The increased use of digital systems in critical infrastructure systems does not just require the resilience of private telecoms networks, it also requires that the digital systems making use of the information from these networks is resilient. For example, water companies will need to develop software and hardware to deal with an exponential increase in data from customers as households transition from bi-annual meter readings to hourly data collected by smart meters. For the overall system to deliver its intended service, these systems, alongside the telecoms networks supporting them, will need to be resilient. Departments, following advice from regulators, should monitor possible threats to services created by reliance on these systems to consider whether clearer or more stringent resilience standards are required.
Ofcom has recently consulted on resilience guidelines for public digital and telecoms networks in the UK. 15 The regulator should seek to review this guidance on a five yearly basis, with a next review in 2028, and government should consider at that point whether changes in levels of dependency on public networks necessitates the setting of customer outcome resilience standards. Any standards may require improvements in the metrics that Ofcom currently use to measure and communicate network performance. Ofcom should keep its information for consumers on these measures of service reliability and resilience under review to ensure it is adequate and accessible to enable consumers to make an informed choice.
For private networks it will ultimately be for government to determine whether the increasing reliance on private networks for critical national infrastructure requires a change in how private networks are regulated. This should be considered as part of five yearly reviews of resilience standards.
In the energy sector the Commission noted that there was already a set of resilience standards covering the ability of the system to transmit and distribute energy through a mixture of legislation and regulation. These standards include requirements for system redundancy, expected levels of system availability and service recovery times. All of these standards will enable or incentivise resilience in the face of events which damage or disable transmission and distribution assets. However, stakeholders agreed that there was no clear understanding of the system’s long term resilience, particularly in terms of its ability to reliably meet electricity demand.
A version of supply standards exists for the gas sector. For gas transmission and distribution the network is required to be designed to be able to withstand the failure of its single biggest asset and still deliver a peak day’s demand in a winter with a five per cent chance of occurring in any given year – or a one in twenty year winter. 16 A draft system performance standard has also now been produced for gas supply. This will require the National Energy System Operator to assess whether the gas supply will be sufficient to meet demand in defined weather events such as a 7, 11 or 15 day cold snap. 17 There is also an existing measure for the electricity system – loss of load expectation – which is defined as the number of hours per year in which supply is expected to be unable to meet demand under normal operation of the system. 18 But this metric is based on an average weather year and does not stress test against extreme conditions such as a wind and solar drought in winter when demand is highest.
In the future it will be more challenging to understand the system’s capacity to supply electricity. There are multiple forms of electricity supply, each with its own risks. For example, the system as a whole will need to cope with a wind drought where a large proportion of wind turbines are not generating. Uncertainties about the future make-up of the system also add to the challenge as consumers increasingly feed into the network as well as draw from it. Consumers feeding domestically generated renewable energy or electric vehicle battery storage into the grid increase the number of unknown variables and while this could make the system more resilient, it increases the challenge of understanding the system’s underlying level of resilience. Uncertainties also arise because different parts of the system are governed by a patchwork of different licences, standards and expectations and no one part of the system has an overarching understanding of how these fit together to deliver overall system resilience.
There are multiple means of building resilience into the system. Government could further strengthen system capacity through the Capacity Market to provide generation at times of system stress, and use the Demand Flexibility Service to incentivise demand reduction. This is broadly how the system is managed today, but government could choose to go further – for example, by developing a strategic energy reserve to deal with severe scenarios, as the Commission recommended in its second National Infrastructure Assessment . 19 This would provide a long term store of energy, though it would still require accompanying generation capacity to ensure the required electricity can be generated. These approaches may or may not be augmented by an overarching electricity supply customer outcome standard, but whichever solution government adopts, it should meet the tests below, raised by stakeholders at the Commission’s energy sector resilience roundtable:
In addition to understanding the impact of climate extremes on the system’s ability to generate and transmit energy, investment in the transmission and distribution system must factor in changes in the climate which might affect asset lives, and therefore maintenance expenditure. Ofgem’s existing Network Asset Risk Metric considers the existing health of assets in the system and the likely efficient funding required to maintain system performance. This metric should incorporate threats to the system from increased deterioration due to chronic stresses caused by changing climate conditions. Distribution and transmission systems should also be stress tested against acute threats including flooding.
Across the energy transmission and distribution systems, the Department for Energy Security and Net Zero should consider how existing measures of future asset health can adequately factor in changes in climate related threats. Across the generation, transmission and distribution systems, the department should consider the existing standards landscape to consider whether an additional future energy supply system performance standard is required to ensure resilient supplies. Indicative timelines for this activity for each sector are set out below.
Ofgem will need to consider whether existing resilience standards for electricity distribution are appropriate as part of the price control process that will begin later this year. Work on resilience should be carried forward in the next electricity distribution price control. Distribution Network Operators should explore what action would be required to maintain their existing service levels in the climate resilience strategies they are required to submit as part of that price control. The Commission will also consider resilience as part of its distribution study and will work with Ofgem and the Department to ensure recommendations in this area can effectively inform the process.
As the price control for the period 2026-31 is already well advanced for electricity transmission and gas transmission and distribution, the Commission recommends that any additional resilience standards could be factored into the following price control (2031-36), with reopeners enabling earlier investment if desirable.
As highlighted above, electricity generation could present new challenges in future as the system’s complexity grows. The National Energy System Operator will be conducting annual risk assessments to set out risks to the system in 1-5 years, 5-10 years and in more than ten years. While it will not be possible to do so in time for the first risk assessment in summer 2025, in future years the National Energy System Operator should quantitatively assess future risks to supply, with government taking action to ensure appropriate levels of resilience are designed into the system as it evolves. The Commission’s second National Infrastructure Assessment has supported this process by modelling future flexibility needs and recommending the development of 60GW of short duration flexibility and 30TWh of persistent flexible generation by 2035. 20
Transport is a critical enabler for the wider economy, ensuring workers can travel to their workplaces and ultimately keeping other critical services such as schools and hospitals open. Yet, as a sector, transport has the fewest resilience standards and measures of the sectors the Commission considered.
The analysis at Annex 1 suggests resilience gaps for National Highways because there are no targets for structural condition, technology availability, drainage resilience or the geotechnical condition of assets. While there are sometimes detailed requirements for new assets, such as a requirement for drainage design for new roads to be resilient to floods with a one per cent annual probability, this does not apply to existing assets. 21 With climate change, it is also likely that the probability of severe flooding will increase, potentially requiring upgrades to drainage even for those roads originally designed to that standard.
In the local roads sector, the position is worse because there is now not only no required condition score for local roads, but there is also no consistent measurement metric. 22 This means it is not possible to compare the condition of local roads in different local authority areas.
For the national rail network there are metrics which consider future asset condition, such as the Composite Reliability Index and the Common Safety Indicators, but these do not consider how future threats such as climate change may alter the future sustainability of the asset base. 23 There is currently no target for expected service recovery times, above and beyond overarching punctuality and reliability metrics which will be more affected the longer services are not recovered.
Ports in the UK operate through three main models: privately owned ports, ports which are run by trusts, and ports which are owned by Local Authorities. All of these ports are subject to safety regulations. 24 Closures of port services can be driven by a range of factors including adverse weather conditions and vessel groundings. Many ports compete for custom, incentivising resilience, because if one port is closed, some shipping can be diverted to another port. However, as preparations for leaving the EU demonstrated, some ports, such as the Port of Dover, are key and irreplaceable nodes in the UK’s transport system. Government should establish a comprehensive list of such key sites and the resilience they are expected to provide. In some instances, major wharves are also safeguarded by the Secretary of State for Housing Communities and Local Government for the purposes of water-borne freight handling. Major wharves should be considered as part of the key sites review. 25
In the airport sector all airports offering commercial services are required to have a safety licence. These include requirements for back up power to keep runway lights on to enable planes to land in emergencies. Both Heathrow and Gatwick are subject to economic licences reviewed by the Civil Aviation Authority and these licenses include resilience conditions. The Civil Aviation Authority also regulates the two arms of air traffic control – control towers at airports which are competitive services, and high air traffic control which is an economic monopoly run by NATS (formerly the National Air Traffic Services). The latter is subject to an economic licence which includes resilience requirements. 26 As with road, rail and ports, government should establish a key route and node strategy which indicates if and where it might require specified levels of resilience for priority routes or airports.
Overall, there are two major potential gaps across the sector:
In the transport sector resilience roundtable, stakeholders highlighted the following considerations when drawing up future resilience standards:
Government should explore filling the gaps the Commission has identified relating to forward looking asset health and a high level resilience strategy for key nodes and routes. Operators report that if they had a high level view, for example setting out that a particular railway line should be almost always operational, while a different specified route can be expected to shut down once a year, they would be able to develop and cost solutions to deliver this. This would then enable government to review these costs and determine whether the overall level of resilience proposed is appropriate. While this review may not be publishable in full due to the security implications of publicly identifying key routes, the Department should consider how it can communicate levels of resilience users can expect from the transport network.
Timelines for filling these gaps are set out below:
Highways investment is driven by the Road Investment Strategy. The next strategy, the third covering 2025-30, is due to be announced shortly. National Highways should develop forward looking asset health metrics to inform their maintenance strategy in this road period and planning for the next strategy, covering 2030-35. A high level timetable for planning is set out below:
Strategic rail investment will be driven by the next control period, which commences in 2029. If government sets out a high level strategic direction, Network Rail can advise how much this might cost and how long this might take to be designed into its systems.
By the end of 2025, to the same timeframe as a high level strategy for strategic roads and rail, government should identify key nodes in the UK’s port and airport networks and set out high level expectations for service resilience. Government should also consider whether the existing governance frameworks are sufficient to support the implementation of desired levels of resilience.
The workshops found that no expected levels of resilience exist for local roads and that there is no consistent metric for comparing the condition of local roads between authorities. In its second National Infrastructure Assessment , the Commission recommended that government devolve five year transport budgets to local authorities in time for the next spending review. The next multi year spending review will run for at least three years from 2026-29. 29 Government should devolve funding in this spending review and, in the longer term, develop a consistent metric for measuring the condition of local roads and set out a high level ambition for a target level of resilience, set out in Local Transport Plan Guidance. In 2023, 20 per cent of local authorities did not share data with the Department for Transport on the proportion of A Roads that should be considered for maintenance. 30 The Department will need to increase its understanding to assess the extent of any maintenance backlog and the timeframe needed to both bridge this backlog and achieve desired levels of resilience.
In its second National Infrastructure Assessment the Commission confirmed its belief that local transport decisions are best taken at local level. In this report the Commission has not been able to analyse the resilience requirements of regional transport bodies under Mayoral Combined Authorities such as Transport for Greater Manchester. However, in order to ensure their services are resilient, regional transport bodies should be clear about the levels of resilience they are targeting, and that this factors in the levels of resilience set out for the strategic road and rail network above.
There is already a set of resilience standards covering the water sector through a mixture of legislation and regulation. However, stakeholders in the water sector workshop agreed that there were notable gaps in expected resilience to peak water demand and in water resource system redundancy. Both of these areas would ultimately lead to water companies receiving regulatory penalties through the Outcome Delivery Incentive for customer supply interruptions but relying on this has disadvantages:
All resilience standards require careful scoping and planning to ensure they do not incentivise unnecessary or poor value for money investments. Below are some considerations for the Department for Environment, Food and Rural Affairs in setting resilience standards for the resilience gaps the Commission has identified.
Water resource systems rely on treatment works treating water continuously, but consumers do not use water at the same volume across a week because usage often looks different on a weekday compared to a weekend and in the daytime compared to the middle of the night. Treated water is therefore stored in service reservoirs so it is available to be put into supply when it is needed. If demand outstrips supply over a long hot period, as was seen in summer 2022, then it is possible that service reservoirs will run out of water and treatment works will not be able to treat and store enough water to supply households. The ultimate result is consumer loss of water supply. This creates the real risk that while the Commission’s estimated £21 billion programme of investment in long term drought resilience will deliver enough raw water to meet needs over a dry summer, water companies may not be able to treat and put this water into supply fast enough to meet daily or weekly demand. 32
When setting a resilience standard to address this problem the department should consider:
There is also a risk that there is insufficient redundancy in the water supply system. In some areas properties rely on a single supply asset and if this fails all of the households supplied will lose access to clean water. This risk may be obscured in the short term. For example, the number of mains serving an area may be reduced from two to one due to cuts in maintenance, meaning an area is vulnerable to single asset failure, but this would not immediately lead to customer supply interruptions. Any standard should consider the system as a whole, from water source to treated water discharged from taps at sub Water Resource Zone level.
When setting a resilience standard to address this problem, the department should consider setting limits on the level of resilience expected. In some areas, such as isolated hamlets, it may not be practical or affordable to develop more than one source of supply. This could be addressed by setting a population cap, by saying for example that no group of more than a set number of houses should be supplied by a single source of supply. The exact cap will need to be determined by cost modelling and discussion between regulators and water companies. Alternatively, companies could undertake risk modelling to understand the probability and consequences of failure from single sources of supply.
Infrastructure operators should also consider single sources of failure caused by system interdependencies when planning to address single sources of supply – such as two sources of supply which rely on the same electricity substation.
As the Commission highlighted in its Chair’s letter to the economic regulator, Ofwat, in 2023, currently the metrics used to assess long term system resilience – mains repairs, unplanned outages, and sewer collapses – are lagging indicators. While they provide information about the condition of assets today, they do not on their own give insight into the future condition of assets because their only data point is the point of failure. At present there does not appear to be a comprehensive and consistent understanding of asset condition across the sector and how this may change in future. A more complete view of asset health in the sector would support a multi-asset management period view of the investment required to maintain asset health and, consequently, service performance and reliability. 34
The Commission identified a gap in resilience standards for wastewater services relating to the risk of sewer flooding. Ofwat has an Outcome Delivery Incentive for companies to reduce the risk of properties suffering internal sewer flooding. Alongside this, Ofwat issues reporting guidelines, though without targets, on the number of properties at risk of flooding from a storm event with a two per cent annual probability – or a one in 50 year storm. 35 This metric is forward looking and designing to a target risk reduction level would improve system resilience to future threats rather than only addressing current system issues. The target would be to reduce the number of properties at risk of being affected, and consequently the number of properties actually affected would reduce over time.
Interventions which reduce the risk of storm related sewer flooding can also help to address the risk of surface water flooding, which has the same cause – heavy rainfall overwhelming the drainage network. The Commission has previously recommended that the government set a long term target for reducing the number of properties at high and medium risk of surface water flooding. It also called for upper tier local authorities, water and wastewater companies and, where relevant, internal drainage boards, to produce joint costed plans to reduce risk. 36 Any metric used to apply a service standard for storm relate sewer flooding should factor in these targets.
The other area where resilience failings have been highlighted – storm overflow discharges – is currently subject to a target of reducing spills to ten a year. 37 While this target may be subject to review, the presence of measurable targets, regardless of the level at which they are set, enables clarity about the desired level of resilience.
There are further considerations which are applicable to all of the resilience gaps highlighted above.
In the water sector, the setting of resilience standards will be too late to influence the 2024 Price Review, so standard setting should be done over the next asset management period to target investment for Price Review 2029 and influence earlier system planning by water companies. The Commission proposes four stages to developing and implementing those resilience standards:
This report has set out issues for government to consider on a sector by sector basis, with a view to enabling the consideration of interdependency risks once sectoral level resilience is revealed. Once these interdependencies are identified it will be for Cabinet Office, as the government body with overall responsibility for resilience, to support departments in identifying how these can be managed. 39 For example, a water treatment works which does not have a resilient electricity supply – because it is supplied by only one source – may find it cheaper to invest in additional back up generation as the cost of additional supply would be too expensive or too carbon intensive. But if several critical infrastructure facilities are located in the same place, it may be more cost effective or less carbon intensive to build a new line rather than expect them all to rely on additional back up generation. As noted above, tools such as the Climate Resilience Demonstrator have shown how data sharing can enable more efficient collective systems level resilience investment.
To support the sharing of information Cabinet Office should consider how it can enable greater data sharing between sectors to avoid individual operators having to engage in lengthy legal discussions on the implications of sharing data.
The below timetable sets out how Cabinet Office could support the management of interdependency risks to ensure efficient and resilient outcomes over the next standard setting cycle:
Capacity market | The Capacity Market ensures security of electricity supply by providing a payment for reliable sources of capacity |
Cascade failure | The failure of one infrastructure system – such as water supply –triggered by failures in other parts of the system – such as electricity supply |
Climate Resilience Demonstrator | A climate change adaptation digital twin project that looks at the impact of flooding on energy, water and telecoms networks |
Demand Flexibility Service | The Demand Flexibility Service aims to incentivise domestic consumers and industrial and commercial users to voluntarily reduce or flex their demand |
Digital and telecoms sector | Fixed and mobile telephony and broadband services provided by telecoms infrastructure |
Forward looking and lagging metrics | Forward looking metrics measure likely system performance into the future, while lagging metrics measure actual system performance today, but not the ability of a system to maintain that performance into the future |
Infrastructure operators | All those owning and operating infrastructure services, systems or assets |
Interdependencies | In the context of an infrastructure system, interdependencies are other infrastructure services that one system relies on to provide its own service |
Metrics | Metrics are means of measuring service performance or quality |
Outcome based service standard/target | Standards or thresholds that are used to express the quality and/or availability of an infrastructure service than an infrastructure provider should aim for |
Outcome Delivery Incentive | An incentive mechanism used by Ofwat to reward water companies for achieving certain target service levels, and to penalise them for failure to achieve them |
Peak demand | The highest level of demand in a system over a short period of time |
Recovery standard | A standard specifying what is expected in the event of a service failure, both in terms of restoration of service and in terms of support services to customers while the service is down |
Redundancy | Additional capacity within a system which means a service can continue to run despite the failure of an individual asset |
Return periods | The annual probability of an event occurring, such as a drought which has an annual probability of ‘returning’ once every 500 years – or has a 0.2 per cent annual probability |
Stress testing | Testing a representation or simulation of a system to reveal its performance under certain conditions or to reveal the conditions that could lead to failure |
System performance standard | A standard that an infrastructure system is expected to meet which may not relate directly to customer experience. For example, a requirement for a system to continue to function in the event of a failure of its largest asset is a redundancy focused system performance standard |
Vulnerability | In the context of infrastructure systems, a vulnerability is a characteristic of the system or weakness in the system that has the potential to lead to partial or full failure of the system |
Water Resource Zone | An area within which the sources of water and distribution of water to meet demand is largely self contained |
The Commission’s report on resilience standards highlights a number of potential gaps in resilience standards that government may want to address in a first round of standard setting. However, a range of customer outcome, system performance and recovery standards already exist across the digital and telecoms, energy, transport and water sectors.
The table below sets out these standards. For the Commission’s purpose a standard is a measured level of service provided to customers, a measured expected level of system performance, a measured speed of service recovery after an outage or required level of service during recovery.
[ Note : due to our website style formatting, references for the elements of the table below are not shown; please refer to the .pdf version of the report for any references]
Sector | Customer outcome standards | System performance standards | Recovery standards |
---|---|---|---|
Digital and telecoms | None | In the telecoms sector, these standards are expected ways of delivering a service. Providers can deviate from this, but would be expected to explain why in the event of a service outage: Ofcom set out redundancy requirements – for example having street cabinets connected to more than one ‘parent’ to avoid single points of failure Ofcom expects core sites in networks to have five days of back up power in the event of a power outage ‘active’ street cabinets – which rely on an electricity supply from the grid - are expected to either be phased out in three - five years or to have four hours of back up generation Ofcom expects core sites to either be located outside the Environment Agency’s Extended Flood Outline or to be able to divert services to another site in the event of a flood | Services signed up to the automatic compensation scheme are required to compensate customers for service outages longer than two working days Landline service providers should ensure customers can contact 999 for at least one hour in a power cut |
Energy | Household and non-household customers without power for at least three hours on more than four occasions are entitled to compensation National Grid Electricity Transmission currently has a target of not more than 147 megawatt hours of electricity not being supplied due to network reliability annually Companies have a target for the maximum amount of time service is unavailable due to unplanned outages Companies have a target for the percentage of uncontrolled gas escapes dealt with in one hour and controlled within two hours The previous government recently consulted on introducing standards for heat networks, including on security of supply | The transmission network operates to safety standards – voltage should not be ten per cent above or below expected voltage for high voltage lines and six per cent for low voltage lines and frequency should not vary by more than one per cent from expected frequency The network is expected to be able to deliver the volume of gas required to meet peak demand in a winter with a five per cent annual probability, despite the failure of the single largest system asset Sub-stations serving more than 10,000 domestic or business customers who cannot be diverted to be another supply must be resilient to a flood with a 0.1 per cent annual probability The electricity transmission system is required to have minimum standards of system redundancy – including that no loss of power should occur as a result of the failure of any single asset | Electricity providers have a 12 hour time limit for restoring supplies in normal weather, rising to 24 or 48 hours in extreme events. Gas distribu-tion companies have 24 hours to re-store supply before compensation is payable Gas and electricity distribution companies are required to maintain a priority services register of vulnerable customers and offer services tailored to need while supply is unavailable The electricity system as a whole is required to be able to restore 60 per cent of regional capacity within 24 hours, and 100 per cent of UK electricity demand within five days |
Transport | National Highways have a target to keep roadworks related delays below a certain impact score measured in weighted lane meter days The rail network has a punctuality target measured by the percentage of stops arrived at more than one minute after scheduled arrival The rail network has a target for the percentage of trains not running all or part of their journey. Within this Network Rail has a Composite Reliability Index with regulatory penalties for service affecting failures Network Rail have different service expectations in adverse cold weather, where punctuality may be affected, and extreme cold weather, where the priority is getting customers home over running a normal timetable | National Highways have a target for 95 per cent of the network’s pavement to require no further investigation | National Highways has a target for 86 per cent of incidents affecting traffic flow to be cleared within one hour |
Water and wastewater | Water companies have targets for reducing the duration of planned and unplanned supply interruptions above three hours and separate targets for unplanned supply interruptions. The unplanned outage standard varies between companies. Water companies have targets to reduce the risk of non compliant water entering supply measured by the Compliance Risk Index Water and wastewater companies have targets for reducing the number of internal sewer flooding incidents per 10,000 connections. This does not vary between companies. Water and wastewater companies have a target for reducing the number of pollution incidents per 10,000km of sewer Water and wastewater companies have targets to ensure their discharged wastewater complies with Environment Agency permits. The level of treatment required depends on the population equivalent served by the works and the water body it is being discharged into | Water companies are given targets to reduce the number of required mains repairs Water companies are given targets to reduce the amount of water lost to leakage Water companies have to meet compliance standards to ensure the safety of raised reservoirs Water companies are required to plan future water resources to ensure resilience to a drought with a 0.2 per cent annual probability Water and wastewater companies are given targets to reduce the number of sewer collapses per 1,000km of sewer By 2050 water and wastewater companies are expected to reduce storm overflow spills to no more than an average of ten spills per year | household customers have a right to payments if their supply is not restored within 12 hours, or 24 hours in the event of a mains burst household customers must be supplied with 10 litres of water per person per day in the event of a supply outage Water companies must maintain a priority service register with bespoke services based on need for registered vulnerable customers in the event of a supply interruption |
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