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MNbS comment: The Independent Water Commission’s (AKA The Cunliffe Review’s) final report.

WWRT NbS project image

As a programme, we are pleased to see a broad alignment between our submission to the IWC’s call for evidence and many of the Commission’s recommendations, in particular:

o The need for a clearer and more integrated long term and cross-sectoral strategic direction.

o Reviewing and simplifying the regulatory framework, with a greater focus on outcome-based delivery and reference to “constrained discretion” (regulatory flexibility) and regulatory sandboxes.

o More flexibility in regulation to allow for innovation and for nature-based solutions.

o Greater integration of planning and governance, including regional water authorities in England and a national systems planner in Wales.

o Sustainable long term funding, including recognition of the need to rebalance spend across capital and maintenance activities, and an increase in catchment funding.

One area where we would have like to see more is in relation to best value and multiple capital approaches. There is some reference to “wider benefits” but it would have been good to see greater recognition of the need to evaluate all of the value – social and environmental – provided by NbS, beyond the purely financial. We are promoting this to the industry and regulators in the form of a Common Value Framework which enables wider evaluation of value.

We are conscious that the IWC recommendations will have major implications for people working across the water sector. Changes to long-standing processes and within regulatory organisations will be creating uncertainty for those who are potentially affected, and we will be mindful of this as we continue our work through the MNbS programme.

Overall, as a programme, we are positive about the IWC’s recommendations and hopeful that they will open new opportunities to increase the scale and use of nature based solutions, so delivering greater value for society and the environment.