CIWEM’s hopes for the Independent Water Commission

24 April 2025

Sir Jon Cunliffe’s review of the water sector is a once-in-a-generation moment for change

In February, the Independent Water Commission (colloquially known as the Cunliffe Review after its chair, Sir Jon Cunliffe) published a mammoth assessment of the challenges faced by the water sector. It also launched a call for evidence, which closed on 23 April. The CIWEM policy team responded to that call, drawing both on submissions from members and ongoing discussion since our work on the A Fresh Water Future report and conference over the last two years. Some clear priorities emerged.

First off, it’s worthwhile to point out that this review will have a significant impact. There is frustration over its scope and breadth, but there hasn’t been a review on this scale since privatisation. In a perfect world, Sir Jon would be looking at every problem in the world of water, from flooding and agriculture to highways and chemicals. Realistically, however, there is only so much his team can tackle in the time available, if we want to see solutions to the most pressing challenges.

To many this is all rooted in the side effects of privatisation. Renationalisation is off the table but there will be opportunities to address regulatory, democratic as well as financial deficiencies. This will be labelled as fiddling, rearranging the deckchairs, greenwashing. But there will be a chance to do many things differently if the review – and then the government – is bold enough.

It’s the system stupid

As with the scope of this review as a whole, the systemic components of the water cycle that join up from a management perspective are many and varied.

Much of the review’s call for evidence focused on economic, planning and wider regulatory minutia. As water management practitioners on the ground, many CIWEM members won’t be innately familiar with this side of things. In feedback from members on the request for input on Cunliffe’s questions, several said that the level of such detail was hard to engage with.

CIWEM's 'A Fresh Water Future' report

Yet they know how water works (or doesn’t). So it’s important that the review unpicks the detail but is still able to see the wood for the trees. Our A Fresh Water Future report found that part of the problem experienced by practitioners was the incremental layering of regulation to course-correct over decades, causing the system to become bloated and confused.

At last year’s A Fresh Water Future conference, Natalie Prosser, the chief executive of the Office for Environmental Protection, said that too many failures have come about not as a result of regulation but because of its implementation. It would be good if the review could understand and address both the macro and the micro-scale issues.

Catchment governance

Setting up a new tier of governance risks legislating for the sake of legislation – exactly what Prosser cautioned against. But done right, this new layer could serve as what commentators are calling the ‘missing middle’. That is, a management function that pulls together all the existing plans and delivery structures and finally gets them working beyond the traditional silos such as water resources, wastewater, nature recovery and flood risk.

This could enable better synchronisation of planning and decision-making, both regionally and across river catchments, making it easier to balance environmental, economic and social priorities. Such a de-siloed approach could also make flows of finance and funding more efficient because of the way it enables multiple benefits from single, wide-ranging interventions.

Strategic ownership of planning and investment priorities and on-the-ground delivery could rest with strategic authorities which are democratically accountable. These would have responsibility for developing so-called spatial development strategies, plans that guide the development and use of land within a specific area. These should help mobilise and direct the parts of the water cycle that aren’t well-engaged at present, such as agriculture and housing. And looked at from the other direction, the strategies themselves will need a resilient water environment to work in the long-term.

Outcomes not process outputs

Another negative impact of the current highly charged political, public and regulatory environment is arguably higher carbon emissions. Regulation has prescribed specific approaches (upstream and downstream continuous water quality monitoring, for example) or driven risk-averse approaches to delivering storm overflow reduction targets.

The current asset management period (AMP8) for water companies in England and Wales, which runs from April 2025 until 2030, is replete with inflexible, expensive, single-outcome, high carbon outputs. These will seriously hinder the progress of the water sector – one of the most energy and carbon-intensive activities in the country – towards net zero. If the Cunliffe review could bring in greater use of carbon metrics – calculations to quantify emissions – within water sector planning and regulation, the next delivery round might look a little greener.

Bringing in more of a local and regional dimension to catchment planning and decision-making should enable a greater focus on delivering national-level policy outcomes in a way that also speaks to the priorities of people who live and work nearby. It may also enable more flexibility on exactly how these outcomes are achieved through better appreciation of local context within the regulatory process. This is likely to need closer strategic alignment between the various water regulators in terms of their priorities.

A national rainwater management strategy

This government’s ambition to demonstrate change following the election seems to have manifested in a lot of building. From houses to major infrastructure, the emphasis seems to be on big numbers and big infrastructure.

Whilst there is a lot of big stuff needed, there is again a need to balance the macro and the micro. The government must be careful it doesn’t miss – or deprioritise – a major opportunity in doing the smaller things close to home.

Big reservoirs, big treatment works, big pipelines and transfers are all needed to support big improvement in water quality and big housing delivery numbers.

But the bigger improvements will come from the combined savings of managing water better at the small scale. This will involve water efficiency, but also a far greater focus on managing rainwater where it falls. From both a drainage and a rainwater harvesting perspective, here is where water company activities have really not been well-integrated with those of housing and urban infrastructure delivery.

It would be a win if the review could recognise this and encourage the government to look beyond big infrastructure and think more about what happens across vast swathes of our urban landscape every time it rains.

Learn more about the Cunliffe review here. You can also read our reflections on CIWEM's A Fresh Water Conference 2024.

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Alastair Chisholm is director of policy at CIWEM