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Citizens Advice response to the National Infrastructure Commission Resilience Study Scoping Consultation

1 April 2019

Citizens Advice response to the National Infrastructure Commission Resilience Study Scoping Consultation [ 170 kb]

In our response to the NIC Resilience Study Scoping Consultation [ 170 kb], we have noted a number of important issues relevant to consumers in the resilience of national infrastructure.

The resilience of the infrastructure of the country, in terms of utility supplies such as water and energy, is vital for consumers to be able to conduct their daily lives effectively and efficiently. Any loss of an essential service can have negative financial and social impacts for an individual or business which differs dependent upon circumstances. Consumers with vulnerabilities, such as ill-health or being in fuel poverty, have much higher negative consequences from outages as they are much less able to independently respond to a crisis. It is therefore crucial that infrastructure companies that are tasked with maintaining our essential services not only ensure security of supply but also have measures in place so that the higher impact of loss of supply on those with vulnerabilities is adequately addressed. Contingency and emergency response plans to manage outages need to be robust, well-thought through, and involve relevant multiple agencies to ensure coverage. Provision within these plans has to prioritise those least able to help themselves.

In the increasingly interdependent world of smart technologies, where one utility service may need to work in combination with another, there will be an increasing risk to resilience of the system. Adequate planning by infrastructure companies will need to account for these increased risks in areas such as cyber security, technical data failings, and also consider any knock-on effects where one essential service fails and impacts others (for example, broadband failures impacting electricity flexibility and Demand Side Response mechanisms).

The infrastructure companies, regulators and policy makers must learn the lessons from major recent incidents, such as the Beast from the East cold-weather event in 2018 and the Lancaster floods in 2015, to formulate robust and socially inclusive contingency plans. Regulators will need to ensure that those emergency plans are fully implemented and prove effective, when the need arises.