Is our approach to water about to get systemic?

Joseph Lewis is Policy Lead at the Institution of Environmental Sciences, working to promote the use of the environmental sciences in decision making. Joseph leads the delivery of the IES Policy Programme, standing up for the voice of science, scientists, and the natural world in policy.

Joseph has ten years of experience in public policy, including in Parliament and the charity sector. He is particularly passionate about science communication and the role it can play in shaping environmental decisions.


At the start of June, the UK’s Independent Water Commission published its interim report, following a call for evidence earlier in the year that received more than 50,000 responses.

This interim report is a critical step in the ‘Cunliffe Review’, which is assessing the water sector regulatory system for England and Wales. With clear evidence of unfavourable environmental and social outcomes over recent years, the Commission will need to determine whether the regulatory system itself needs to change, and how it can better secure outcomes for people, the economy, and the environment. 

From the outset, the Commission has been seeking to provide recommendations amounting to a ‘fundamental reset’ of the water sector. This interim report sets out initial findings, with a final report due to be released over the summer.

For an early look at the review and what it means for the environment, see our Essential Environment coverage from March. For an IES perspective on the review so far, see the IES and FWR response to the Commission’s call for evidence.

What does the interim report say?

The interim report focuses on the same five core themes as the call for evidence:

  • strategic direction and planning
  • legislative framework
  • regulatory reform
  • company structures, ownership, governance and management
  • infrastructure and asset health

The most important aspect of the interim report is the recognition of the need for a wider systemic approach to water, exemplified in the report’s statement that “there is no simple, single change, no matter how radical, that will deliver the fundamental ‘reset’ of the water sector that is the governments’ objective.” 

Other aspects of the interim report examine:

The big picture

  • System planning for water: The interim report recognises the importance of system planning, particularly at the regional level where water catchments offer a natural and strategic scale for planning. While the interim report does not commit the Commission to a final stance, it suggests that current thinking favour system planning at a scale "mapped to hydrological boundaries", which could help to facilitate integrated water management.
  • Rationalising the legislative framework: Rules and legislation around water are complex, stemming from multiple policy sources and (in the words of the Commission) “successive, and often piecemeal, legislative changes”. Making that system less complex and more rational would be a positive outcome, as long as any changes made by the Government reflect the Commission’s recognition that “a strong legislative framework is important for ensuring that management of water meets the requirements expected by society”.

How to improve public trust

  • Regulation in practice: The interim report recognises a loss of public trust in the current system of regulation, calling for “an objective, industry-wide benchmarking framework” that goes beyond a ‘one-size-fits-all’ approach. Depending on what it would like, this could be good news for consumers, particularly if it delivers the Commissions call for “a fundamental strengthening and rebalancing of the current approach to economic regulation”.
  • The future of water companies: There are still open questions in the interim report about what the Commission will recommend around water companies, though it has indicated that a key priority will be embedding long-term perspectives and seeking to “restore the stability and predictability of the regulatory system that is necessary to attract such low risk, low return investors”. While the interim report suggests that further governance requirements are unlikely, the final report may make further recommendations on duties for senior management.

Opportunities and trade-offs

  • A longer-term strategic view: The interim report calls for “clearer, long-term strategic direction from government”. In theory, a longer-term and more strategic approach would be a very welcome development, as long as the “priorities and trade-offs” made by the UK and Welsh governments lead to better outcomes. In the context of increasing politicisation around nature and the environment, this change would depend entirely on whether the right trade-offs are made in the right way.
  • Improving resilience: The report recognises that challenges remain for asset health and resilience, including the resilience of the system as a whole. It further argues that there is “a strong case for setting a forward-looking infrastructure resilience framework and standards at a national level for England and Wales respectively”, which could be a welcome opportunity to join up resilience efforts across different dimensions of the environment.

For full details of the Commission’s findings so far, see the interim report.

How have the experts responded?

IES members and committee members have responded to the latest developments:

This interim report is a great insight into the Commission’s current thinking. It offers an initial perspective on a more systemic approach to tackling water, which would be welcome in light of the increasingly ‘wicked’ problems facing the sector.

This is only part of a wider policy process, but eventually outcomes will depend on the work of practitioners, who must be ready to deliver. This interim report should be viewed as a vindication of the choice by environmental professionals to develop systemic, multidisciplinary approaches, which will be critical to implementing system planning in practice.

- Gary Kass, Chair of the IES External Policy Advisory Committee, IES Vice President

The Independent Water Commission’s call for a regional ‘systems planning’ approach highlights the critical need to move beyond siloed decision-making. Evidence from our recent collaborative work with the Environment Agency and Mott MacDonald team demonstrates that coordinated, systems-based planning, integrating water resources, quality, and high flows management, can support the design of multifunctional interventions with co-benefits across sectors. 

Such an approach improves planning effectiveness, enhances system resilience, and enables better alignment with local development and environmental priorities. Integrated modelling tools such as WSIMOD are essential to underpin this process, providing the systems-level evidence required for collaborative and transparent decision-making.”

- Ana Mijic, Professor of Water Systems Integration, Imperial College London

What does it mean for you?

While this interim report is an important milestone, setting out a clear indication of the Commission’s perspective so far, we are still several steps away from seeing the full implications for environmental professionals.

Over the summer, the Commission is expected to produce a final report, which will set out recommendations. Ultimately, the Welsh Government and the UK Government will need to decide whether or not to adopt the recommendations in Wales and England respectively. They also need to decide how to implement the recommendations, as the Commission is likely to leave a degree of discretion around the more strategic and political questions.

For water professionals, the immediate implication is that systemic change is on the horizon. Professionals should get ‘upstream’ of these developments by considering how they can embed multidisciplinary approaches and how tools such as WSIMOD can help them to prepare for a strategic shift. We should also be considering how we can seize the opportunity of systemic and catchment-based approaches to secure co-benefits and shared outcomes for people, the economy, and the environment.

What are we doing about it?

The Foundation for Water Research (FWR) is a key part of the IES family, working to champion a systems approach to ensure that water solutions are holistic and multifunctional. The research and work of the FWR will be crucial to delivering on these latest calls for a long-term systems approach to water.

In the last week, Patric Bulmer has written a timely analysis piece for the FWR website on water resources management and infrastructure, looking at ‘the challenges and the future’.

Get involved: if you want to support the work of the IES to stand up for science and nature, become an affiliate member, or if you’re an environmental professional, join the IES. If you want to find out more about environmental policy or the training we offer for members, please contact Joseph Lewis, IES Policy Lead (joseph@the-ies.org).

Image credit: © Andy via AdobeStock