EU Commission guidance - climate proofing infrastructure

Commission adopts new guidance on how to climate-proof future infrastructure projects.

Executive summary
The European Union Commission has recently published technical guidance on climate-proofing of infrastructure projects for the period 2021-2027 (the Guidance). This forms part of the Commission's wider focus on sustainability guidance, and will be an important feature of future assessments for infrastructure, whether that is large scale housing developments, network infrastructure (transport, energy, information and communication technologies and water), and a wide range of built systems and assets. It will therefore be a vital consideration for developers and all stakeholders (expert consultants, local authorities and the public), as these projects are built in the years ahead.  

What is climate proofing?
Simply put, it is the process for integrating climate change mitigation and adaptation measures into the development of infrastructure projects. It is intended to help investors make informed decisions about projects that are climate resilient and compatible with climate change goals. The key climate change goals are the achievement of a 55% reduction in carbon emissions by 2030 (compared to 1990 levels) and carbon neutrality by 2050. 

The process has two pillars – mitigation and adaptation:

• Mitigation - mitigating climate change requires a reduction in the flow of heat-trapping greenhouse gases into the atmosphere, and can be done by switching to low-carbon energy sources such as wind power, solar and hydroelectric technologies.
• Adaptation – adapting to life in a changing climate involves adjusting to actual or expected future climate. The goal is to reduce our vulnerability to the harmful effects of climate change (like sea-level encroachment and more intense extreme weather events) and to ensure the climate resilience of infrastructure developments. Analysing the vulnerability of a project to climate change is crucial to identifying the right adaptation measures to take. The analysis is broken down into three steps: (i) sensitivity analysis, (ii) an assessment of current and future exposure, and then (iii) a combination of the two for the vulnerability assessment.

Identifying key climate change issues early on in a project is crucial 
The Guidance notes that projects listed in Annex I and II of the EIA Directive will usually warrant climate proofing. Both the impact of the project on climate and climate change (i.e. climate mitigation) and the impact of climate change on the project and its implementation (i.e. climate adaptation) should be considered early on in the EIA process.

The Guidance emphasises that when addressing climate change adaptation concerns as part of EIA, one should not only consider the historical data on climate. The Guidance's focus is on climate modelling regarding future risks, rather than modelling based purely on prior history. This is notably directed at the fact that in many cases, projects need to be designed to withstand very different environmental conditions from historical or current ones.

Developers/consultants will also need to outline how extreme climate situations are taken into account as part of the environmental baseline analysis in any assessment. The evolution of the baseline (i.e. how the current state of the environment is expected to change in the future) will be critical to understanding how the proposed project might impact that changing environment. The Guidance provides a series of questions that should be raised and factors to be taken into account. 

Conclusion
Infrastructure projects need to take account of the likely significant changes in the frequency and intensity of extreme weather events which will occur due to climate change. Those impacts are already happening, and will only intensify in the future. Stress testing infrastructure projects for higher levels of global warming (whether that is 1.5 degrees, 2 degrees or 3 degrees) through the climate vulnerability and risk assessments will only grow in importance in the years ahead. Projects will need to include a methodology and approach for how to plan and explain its approach to climate proofing, along with any of the limitations identified. Depending on the specific nature of the project, this may include bringing in a climate-proofing manager and a team of experts in climate change mitigation and adaptation. 

For more information please contact Alan Roberts, Partner, Alison Fanagan, Consultant, Mark Thuillier, Associate, or any other member of the Environmental and Planning team.

Date published: 21 September 2021