The Water White Paper: A deep dive into the regional water planning framework proposals

This article explores the move towards a holistic, system based regional water planning framework endorsed by the Water White Paper, following the recommendations of the Cunliffe Review.

The Water White Paper sets out proposals for a fundamental reform of regional water planning in England. These proposals are best understood as the Government’s direct response to the Independent Water Commission’s (the “Commission”) Cunliffe Review (the “Review”) and propose a systems‑based, long‑term approach into a new institutional framework for regional planning.

Our earlier articles explored the key themes and reforms and the specific proposals in respect of the Cunliffe recommendations that are relevant to the planning and consenting of water infrastructure. In this article, we take a closer look at the proposed regional water planning framework.

At present, regional River Basin Management Plans (RBMPs) are supported by Water Resource Management Plans (WRMPs) as well as up to 9 different internally developed plans that support business planning. These include regional resource management plans, drought plans, drainage and wastewater management plans, pollution incident reduction plans, drinking water safety plans, water industry national environment plans and national environment plans, long term delivery strategies. In addition, the industry must have regard to 18 further plans which interact with their planning to include flood risk planning, local growth and development plans, or local nature recovery strategies.

These plans have varying renewal periods, and often see priorities split between different plans. The Commission’s Review points to the complexity of the current structure of plans which is leading to inefficiency. The Office for Environmental Protection has stated that the failure of River Basin Management Plans to deliver outcomes has led to a range of environmental and resource issues. In addition, the Commission noted that whilst regional water resources groups, who generate the regional resource management plans (RRMPs), have received positive feedback, they lack a holistic approach. These RRMPs bring together a national picture of challenges regarding water supply and how it should be addressed, but they have no standardised planning methodology, statutory underpinning or security of funding – their focus is solely on water resources. The Commission states that there is no equivalent focus on drainage or waste waster meaning that there is no holistic approach for catchments or river basins. The Commission has identified this as a lost opportunity to target action where there are co-benefits.

The Commission, therefore, proposed a broad approach which seeks to bring greater alignment with water system planning and other forms of spatial planning. The White Paper confirms that a structural overhaul is required and that the Government is looking to enable “an enhanced better joined-up regional water planning function”. These will likely build on the existing water resource planning process. 

With a timeline of preparing for new elements of the regional water planning function in 2026, along with doubling funding for catchment partnerships to strengthen local capacity to deliver effective catchment planning, the Government is seeking to implement the new model from 2027.

The White Paper leaves the details of the new model to the forthcoming Transition Plan. It is likely that these will follow the recommendations in the Review, which we have highlighted below.

Functions of the proposed framework:

• A System Planner: The Commission suggests that a system planner (in England, a regional water authority; in Wales, a national authority) should be responsible for convening and delivering a new holistic plan to set, deliver and monitor objectives.

• Missing Middle: Plans should sit directly underneath National Water Strategies and Ministerial Statements to ensure that they are the principal delivery mechanism for a government’s strategic direction. These plans should cover both the water environment and water supply to ensure that environmental objectives and resource planning can be dealt with through a single route. They should also look to tie into other regional spatial priorities, such as Local Nature Recovery Strategies, Future Wales: the National Plan 2040 and tools such as the Land Use Framework.

• Funding: The Commission has suggested that the system planner should be able to direct funding towards regional and national objectives, be given direction over water company enhancement expenditure and have some control over government funding in the water system.

• Water objectives: The Commission suggest moving the process of setting environmental objectives for water bodies from the RBMPs to the system planner which represents a significant structural shift. RBMPs are not intended to be abolished, but the aim is to create a vehicle that links objectives, funding and water resource to improve delivery.

• Monitoring of objectives: Whilst it is noted that overall responsibility for monitoring water industry plans should remain with regulators, the system planner should be responsible for high level monitoring with a strategic board tasked at deciding whether corrective action is needed to meet objectives. This monitoring should inform an evaluation exercise on the plans.

• System interaction: The Commission suggest that regulators should have an advisory role to the system planners in the objective setting stage to ensure alignment between objectives and legal requirements.

Geographic Scale: The Commission suggests that the regional plans in England should largely follow the River Basin Districts with alterations made to account for cross-border differences. The suggestion for Wales is that a single plan is established which looks to split responsibility for the Severn River Basin District along the border.

Convening and Consultation: The Commission suggests that system planners should play a wider role and provide regular forums for discussing system issues and take on co-ordination for water planning consultations. It recommends that funding should be increased to strengthen this approach.

Influence over non-water sectors: It has been suggested that system planners should have a role in directing environmental land management funding towards water system priorities. Additional mechanisms are also needed to mitigate the impact of key sectors including agriculture and highways, with clear guidance set out for what existing levers can be used to improve compliance with legal requirements. The Commission has suggested that the system planners form statutory consultees to Spatial Development Strategies and Local Plans.

Next Steps

The Government is not required to follow the recommendations of the Cunliffe Review, however, given the broad support for the findings of the Commission in the White Paper, there is good basis to assume that many of the suggestions highlighted above will find their way into future guidance and regulations.

What is clear from the White Paper is that there is an intention to drive this structural movement forward quickly and effect a genuine change in the current system. The proposals also fit within the move towards a spatial planning approach, with more strategic thought going into what infrastructure is required where. This will be relevant to all water industry practitioners and to planners in general who will need to get to grips with a shift in focus and balance in the water planning process.

We will continue to publish updates on the specific proposals in the White Paper as more details emerge, but please do contact Jen Ashwell, Director, or Doug Haycock, Associate, if you have any queries in the meantime.