Section 3 of 5
Assessment of the draft plan
Judged against the evidence, the draft is a genuine first step with real strengths — and several weaknesses that determine whether it changes anything. Criticism here is aimed at what the document does and does not do, not at the people who wrote it.
First, what is genuinely strong
- Precautionary scenario. Planning against high-warming (SSP5-8.5) rather than the comfortable middle is the right call for a plan that will shape 2050s decisions.
- Honest about inequality. The draft connects deprivation to exposure — Bretton, Dogsthorpe, Eastfield, Welland and others appear repeatedly in flood and heat zones — and frames adaptation as fairness, not just engineering.
- Nature-based measures with named partners. Wetlands, SuDS, tree corridors and pollinator work are scored and assigned to real local bodies (Nene Rivers Trust, Nene Park Trust, PECT, catchment partnership).
- Alignment with duties that already exist. It plugs into the Local Flood Risk Management Strategy, biodiversity net gain, the Local Nature Recovery Strategy (published December 2025) and the EA's emerging Nene Water Management Strategy.
- Honest about its own limits. The draft admits delivery could stall without money and political priority — which makes the gaps below hard to dispute.
1 · Delivery: a plan with no engine
The draft recommends an adaptation officer, a steering group, KPIs and annual public reports. None of these is established by the document; there is no committed budget, no named owner and no start date. The 2026/27 budget and three-year financial plan approved by Full Council in February 2026 mention climate change nowhere (a keyword search of the full documents finds zero mentions). The council's finances are stabilising — a £2.6m overspend in 2025/26, exceptional financial support approved in 2026 — but adaptation has no line in them.
This is not a Peterborough-specific failure. The Climate Change Committee's 2025 statutory report finds the UK's preparations "inadequate" with no outcome scored good; research for the CCC finds no statutory duty on English councils to plan adaptation, only about a quarter hold climate risk registers, and council officers say adaptation "cannot be effectively delivered on the current funding model". The grant that paid for Peterborough's plan — the Shared Prosperity Fund — closed in March 2026, replaced by a growth-focused Local Growth Fund. The pattern is national; the risk is local: without an owner and a budget, this plan becomes a well-written shelf document.
2 · Policy teeth: adoption is not enforcement
Adopted, the plan is a corporate strategy with no direct planning force. The document that could give it teeth is the new Local Plan (2024–2044) — whose pre-submission consultation, expected around now, has been postponed. The most recent draft Local Plan (consulted April–May 2025) already carried a sustainability objective on climate change adaptation and policies on flood risk, green infrastructure, water efficiency and biodiversity net gain; the version that eventually goes to examination will be judged against the rewritten NPPF of August 2026, which requires plans to consider current and future flood risk from all sources and overheating in new development. Until the Local Plan catches up, new development is consented against weaker, older policy — while the adaptation plan's own evidence shows the riskiest wards.
Two national gaps matter here too: mandatory SuDS approval (Schedule 3 of the Flood and Water Management Act) is still not in force in England, and the Future Homes Standard's overheating and efficiency rules only apply to buildings consented after it takes effect (March 2027, with transitions). Nothing in the draft adaptation plan can close those gaps locally — but the council can use every planning tool it already has, and say so publicly.
3 · People: the existing-homes problem is under-addressed
The draft's "Protect People" measures — heatwave alerting, checks on isolated residents, cooling centres, care-home support — are sensible and overdue. But the people most exposed to 30 °C+ days and flood damage live in the city's poorest-quality housing: 24.5% of households rent privately, the council has owned no housing stock since 2004, and retrofit of existing homes appears mainly as aspiration. The licensing schemes the council does operate (selective licensing 2024–29, additional HMO licensing from January 2026) are not mentioned as adaptation levers — for example setting minimum overheating or flood-resilience expectations through licence conditions. Roughly 14,000 residents are aged 75+, the group most at risk in heat and most likely to be offline when warnings are digital.
4 · Water: hard questions deferred to Anglian Water
The drought chapter is the thinnest. Demand-side measures are good (rainwater harvesting, water efficiency, community food growing), but supply-side resilience is largely delegated to Anglian Water — the company whose leakage fell 3.9% against a 16.4% target over 2020–25, whose customers face a £140 (+29%) bill rise by 2030 under the AMP8 settlement, and whose July 2026 hosepipe ban was its first in a decade. The Fens Reservoir proposed near Chatteris will not supply Peterborough. The River Nene through the city is at Moderate ecological status, with monitored sewage overflows spilling for hundreds of hours a year. A credible adaptation plan should say what it will hold Anglian Water to — leakage, overflow reduction, the Ruthamford North supply resilience — rather than listing "collaborate with Anglian Water" as the measure.
5 · The consultation itself
Six weeks is short but lawful for a non-statutory consultation, and the council deserves credit for consulting at all on a document most councils never produce. Three weaknesses stand out:
- Digital only. The survey is a Microsoft Forms page with no paper, telephone or in-person route announced — unlike the council's own budget consultation in late 2025, which offered library hard copies. Ofcom finds 20% of over-75s have no home internet — the very group the plan's heat measures target. (The survey is English-only, with no Easy Read or translated version found.)
- No way to check who responded. The survey contains no demographic or equality questions at all, so the council cannot tell whether respondents represent the city — or just the digitally confident.
- No published route for results. The council says the plan "will be updated following the consultation and will be considered for adoption", but no committee date, results report or adoption timetable is published. (The consultation itself was also delayed eight months from its planned January 2026 start, with no published reason.)
Verdict
As an evidence base and menu of options, the draft is a solid, honest piece of work that names the right problems — including the uncomfortable overlap of deprivation with flood and heat risk. As a plan, it is unfinished: no money, no owner, no planning force, thin on existing homes and on holding the water company to account, and consulted on through a channel that will miss many of the people it is meant to protect. Every one of those gaps is fixable — most by the council itself, and the recommendations section sets out how.